08.02.2023 Update: Provision for transition from imputation system to h ... The German Federal Constitutional Court has ruled that the transitional provision from the imputation system to the so-called half-income method in the course of the Annual Tax Act 2010 is partially incompatible with the German Basic Law and obliges the legislator to retroactively eliminate the identified constitutional violation by 31 December 2023. Categories: Constitutional CourtKeywords: imputation system
10.06.2015 Imputation credit for foreign corporation tax refused Despite apparently favourable ECJ judgments, the Supreme Tax Court has once again refused a taxpayer credit for the foreign corporation tax due on a dividend received during the currency of the old, imputation tax System. Categories: Supreme Tax Court casesKeywords: imputation, imputation system, Foreign T ...
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 ...
