08.02.2019 European Court of Justice: Deductible input VAT of a branch ... In its judgment in Morgan Stanley (C-165/17) on 24 January 2019, the ECJ ruled on the ratio of deductible input tax in relation to the internal supplies of a French branch to its head office, a financial service provider in the UK. Categories: From EuropeKeywords: Financial Services (FS) / Finanzdienstle ...
01.01.2017 Administration publishes regulations on branch profits On December 22, 2016 the finance ministry has finally published its detailed administrative principles on the allocation of profits between a business and its foreign branches. Categories: Official PronouncementsKeywords: permanent establishment (PE), branch, AO ...
07.10.2015 Post-dissolution profits and losses from foreign P.E. attrib ... The Supreme Tax Court has held that the profit from the release of a provision no longer required arising from a foreign permanent establishment long after closure falls under the business profits clause of the relevant double tax treaty and is thus taxable in the foreign country. Categories: Supreme Tax Court casesKeywords: permanent establishment (PE), branch, pr ...
09.07.2014 No deduction for preparatory costs of failed foreign PE The Supreme Tax Court has held that a taxpayer cannot deduct costs incurred in preparing for a foreign permanent establishment even if, in the event, the establishment never came into existence. Categories: Supreme Tax Court casesKeywords: branch, preparatory costs, Foreign Perma ...
21.03.2013 Old corporation tax rate on German branch income of non-EU c ... The Supreme Tax Court has held that the corporation tax rate on the permanent establishment income of non-EU foreign companies under the old, pre-2001 system was acceptable under community law and the double tax treaty. Categories: Supreme Tax Court casesKeywords: permanent establishment (PE), branch, im ...
