Schlagwörter: retroactive merger (2 gefunden)

1. 27. Dezember 2024

   Merger with retroactive tax effect: No offset of profits fro ...

   According to a recent judgment of the Supreme Tax Court, Section 2 (4) sentence 3 of the Reorganization Tax Act also prevents offsetting positive income generated during the retroactive period by the transferring legal entity with a loss carry-back of the acquiring legal entity from the following (post-merger) year.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: loss carry-back, retroactive merger
2. 23. Februar 2021

   No tax effect on income of deceased shareholder after retroa ...

   The Supreme Tax Court held that a merger with retrospective tax effect does not lead to a merger profit for a former and meanwhile deceased shareholder of a limited company even if the shares were acquired gratuitously after the effective (retroactive) tax transfer date.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: merger profit, retroactive merger, decea ...