03.03.2015 No objection to 10 year tax deferral on transfer of assets a ... An ECJ advocate general has suggested the court rule that a German practice of allowing deferral of taxation on the hidden reserves (appreciation in value) in intangible assets transferred abroad is proportional and reasonable in the light of the overall need to ensure a fair distribution of taxing rights between member states. Categories: From EuropeKeywords: hidden reserves, intangible assets, inte ...
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 ...
08.09.2011 Dutch exit tax excessively burdensome? An ECJ advocate general has suggested the court accept in principle the Dutch exit tax on business, but require deferment of the actual levy until the relevant assets are realised. Categories: From EuropeKeywords: hidden reserves, exit tax, final settlem ...
27.01.2011 Share exchange on merger at nominal value releases hidden re ... The Supreme Tax Court has held that a share exchange at nominal value leading to a transfer of hidden reserves abroad triggers a taxable capital gain for the transferring shareholder. Categories: Supreme Tax Court casesKeywords: capital gain, hidden reserves, Share exc ...
