12.04.2016 Treaty improved tax credit not a TFEU infringement? An ECJ advocate general has suggested that a tax treaty can justify a hindrance on the free movement of capital from granting a tax credit privilege to recipients of a dividend from a third country but not to those with dividends from a member state. Categories: From EuropeKeywords: withholding tax, free movement of capita ...
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 ...
30.04.2015 Continued German tax liability under DTT does not conflict w ... An ECJ advocate general has suggested the court rule that there is no conflict between the discrimination prohibition of the EU/Swiss free movement agreement and the Swiss/German double tax treaty provision for the continued German taxation of German source income of a former resident. Categories: From EuropeKeywords: Switzerland, discrimination, free moveme ...
25.04.2012 German trade tax restriction on interest deductibility uphel ... The Supreme Tax Court has upheld the German disallowance of one-half of the long-term interest expense for trade tax as not conflicting with the Interest and Royalties Directive and not infringing the German/Dutch tax treaty prohibition on discrimination. Categories: Supreme Tax Court casesKeywords: add-back, Inerest deduction, long-term i ...
20.01.2011 Inheritance tax on foreign holding referred to ECJ The Supreme Tax Court has referred to the ECJ on a refusal to grant the same inheritance tax allowance on a holding in Canada that would have been available on a domestic investment. Categories: Supreme Tax Court casesKeywords: free movement of capital, foreign invest ...