09.06.2021 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. Categories: LegislationKeywords: ATAD, dividend withholding tax, Income T ...
05.04.2016 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. Categories: Official PronouncementsKeywords: income adjustment, arm's length, Foreign ...
19.11.2015 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. Categories: From EuropeKeywords: discrimination, former resident, Foreign ...
10.06.2015 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. Categories: Supreme Tax Court casesKeywords: imputation, imputation system, Foreign T ...
26.11.2014 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. Categories: Supreme Tax Court casesKeywords: income adjustment, interest-free loan, f ...
30.06.2011 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. Categories: From EuropeKeywords: Meilicke, imputation, foreign dividend, ...
09.01.2011 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. Categories: Supreme Tax Court casesKeywords: Active business, contracted out, CFC pro ...
