Schlagwörter: Foreign Taxes Act (8 gefunden)

1. 14. August 2025

   Federal Ministry of Finance publishes draft bill for a Minim ...

   On August 6, 2025, the Federal Ministry of Finance (MoF) sent the draft bill for a law to adjust the Minimum Tax Act (“MTA”) and implement further measures (“MTAA – Draft”) to the associations for comment by August 11, 2025. The draft bill includes measures for the implementation of the OECD Administrative Guidance on Article 9.1 of the Global Anti-Base Erosion Model Rules from January 2025 as well as “accompanying measures" that are intended to contribute to the simplification of international tax law ("decluttering") outside the scope of the MTA.

   Kategorien: Official Pronouncements, Tax & Legal New ...

   Schlagwörter: CFC provisions, minimum taxation, Foreig ...
2. 09. Juni 2021

   UPDATE : Bundestag passes the Act to Modernise the Relief of ...

   On 5 May 2021, the Bundestag passed the Act to Modernise the Relief of Withholding Taxes and the Certification of Capital Gains Tax. The law as passed is based on the resolution recommended and passed by the Bundestag Finance Committee on 21 April 2021.

   Kategorien: Legislation

   Schlagwörter: ATAD, dividend withholding tax, Income T ...
3. 05. April 2016

   No conflict between Foreign Tax Act and tax treaty definitio ...

   The finance ministry has decreed that Supreme Tax Court judgments limiting the income adjustments under the Foreign Tax Act to questions of amount are not to be followed as precedents prohibiting adjustments by reason of the nature of the transaction under review.

   Kategorien: Official Pronouncements

   Schlagwörter: income adjustment, arm's length, Foreign ...
4. 19. November 2015

   ECJ confirms German extended limited tax liability

   The ECJ has held that the continued liability to German tax on German sources income of a former resident is not discrimination prohibited by community law.

   Kategorien: From Europe

   Schlagwörter: discrimination, former resident, Foreign ...
5. 10. Juni 2015

   Imputation credit for foreign corporation tax refused

   Despite apparently favourable ECJ judgments, the Supreme Tax Court has once again refused a taxpayer credit for the foreign corporation tax due on a dividend received during the currency of the old, imputation tax System.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: imputation, imputation system, Foreign T ...
6. 26. November 2014

   Income adjustment for interest-free loan to foreign subsidia ...

   The Supreme Tax Court has held that an income adjustment for the interest lost on an interest-free loan to a foreign subsidiary can be made under the Foreign Tax Act unless the loan was granted as a substitute for share capital.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: income adjustment, interest-free loan, f ...
7. 30. Juni 2011

   Maximum imputation credit for foreign tax is amount paid

   The ECJ has held that the foreign tax imputation credit on a dividend received from abroad is the lower of the corporation tax shown to have been paid abroad and the income tax due on the dividend by recipient.

   Kategorien: From Europe

   Schlagwörter: Meilicke, imputation, foreign dividend, ...
8. 09. Januar 2011

   Active business can be contracted out

   The Supreme Tax Court has held that a Dublin docks reinsurance company that subcontracted its operation under a management agreement was an active business within the meaning of the Foreign Tax Act.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Active business, contracted out, CFC pro ...