16.05.2017 Curtailment of loss relief for companies in part unconstitut ... The German Constitutional Court held that the rules for curtailment of loss relief on change of shareholders to be in breach of the formal provisions of the constitution under the principle of equal treatment insofar as changes of more than 25% and up to 50% of the shares in a company within a period of five years are concerned. Categories: PwC ReportsKeywords: Loss relief, curtailment of losses, chan ...
13.01.2017 Amendment of tax loss utilisation rules for corporations Under certain conditions, changes in shareholders and the admission of new investors will in future be possible without giving rise to a forfeiture of losses carried-forward. On 23 December 2016 the Act for the Further Development of Tax Loss Utilisation for Corporations was published after having been adopted by the German Parliament (Bundestag and Bundesrat) on 20 December 2016. Categories: PwC Reports, LegislationKeywords: Corporation tax, curtailment of losses, ...
12.02.2013 Pre-accession relief rule applicable until Commission rules ... The advocate general on an ECJ case on special case exemption from a loss curtailment provision has suggested the court hold the exemption rule to be of pre-accession provenance and thus not to be disapplied as unauthorised state aid unless and until the Commission has come to that conclusion on the basis of a properly completed formal proceeding. Categories: From EuropeKeywords: Loss relief, curtailment of losses, chan ...