Tax & Legal

Categories: All (5 found)

1. 28.02.2019

   ECJ provides guidance on beneficial ownership and abuse of r ...

   On 26 February 2019, the ECJ issued its judgements in the joined cases T Denmark and Y Denmark -v- the Danish Ministry of Taxation (C-116/16 and C-117/16) and N Luxembourg 1, X Denamrk A/S, C Danmark I and Z Denmark ApS -v- the Danish Ministry of Taxation ( C115/16. C-118/16, C-119/16 and C-299/16).

   Categories: European Court of Justice

   Keywords: beneficial owner, Parent/Subsidiary Dire ...
2. 26.06.2018

   Current version of German anti-treaty shopping legislation i ...

   On 25 June 2018, the European Court of Justice published its decision of 14 June 2018 concerning the current version of the German anti-treaty /anti-directive shopping legislation.

   Categories: European Court of Justice

   Keywords: freedom of establishment, Parent/Subsidi ...
3. 02.05.2018

   Federal Ministry of Finance amends earlier circular on treat ...

   On 20 December 2017 the European Court of Justice (ECJ) took the view that Section 50d (3) Income Tax Act prohibiting certain intermediary foreign companies from (full or partial) refund of German withholding tax was incompatible with both the Parent-Subsidiary Directive and the freedom of establishment. The German Tax Authorities have recently issued a circular on its application of the rules.

   Categories: Official Pronouncements

   Keywords: Parent/Subsidiary Directive, refund clai ...
4. 15.03.2017

   Subject-to-tax requirement of the Parent-Subsidiary Directiv ...

   The subject-to-tax provision of the Parent-Subsidiary Directive, whereby distributed dividends are exempt from withholding tax, requires that the dividends are taxed in the hands of the parent company. In practice, this necessitates actual payment of the tax.

   Categories: From Europe

   Keywords: Parent/Subsidiary Directive, subject-to- ...
5. 09.07.2013

   Withholding tax exemption on dividends on shares held in ban ...

   The finance ministry has announced the arrangements for claiming withholding tax exemption under the EU Parent/Subsidiary Directive on dividends on shares held in the custody of a bank.

   Categories: Official Pronouncements

   Keywords: withholding tax, dividend, Parent/Subsid ...