10.05.2024 Assessment basis for VAT upon transfer of immovable property ... The ECJ decided in a polish case that the taxable amount of a contribution of property by one company to the capital of a second company in exchange for shares in the latter must be determined based on the issue price of those shares if the parties mutually agreed to that effect. Categories: European Court of JusticeKeywords: Share exchange, contribution in kind
13.01.2016 Consideration in kind valued on day of contract fulfilment The Supreme Tax Court has held that the capital gain on the exchange of shares is realised when the shares are delivered but should be based on the value of the shares received when received. Categories: Supreme Tax Court casesKeywords: contribution in kind, consideration in k ...
23.01.2014 German rule on taxation of hidden reserves on contribution o ... The ECJ has upheld a German rule providing for immediate taxation (but with a deferral option) of the capital gain inherent in the excess of the market over the book value of a business transferred to a corporation in exchange for shares where as a result of the transaction Germany would lose the right to tax the gain on any subsequent sale of the shares. Categories: From EuropeKeywords: capital gain, hidden reserves, contribut ...
17.08.2011 Contributions under Reconstructions Tax Act 1995 always at r ... The Supreme Tax Court has held that the value of a contribution in kind under the Reconstructions Tax Act 1995 as taken up by the recipient is binding on the contributor. Changes in retrospect are binding on both parties. Categories: Supreme Tax Court casesKeywords: contribution in kind, contributor