01.09.2023 Government bill for a law to implement the global minimum ta ... On Wednesday, 16 August 2023, the Federal Cabinet adopted the government's draft bill on the implementation of Council Directive (EU) 2022/2523 to ensure minimum global taxation with other accompanying measures. The draft was officially published on 17 August 2023 Categories: LegislationKeywords: OECD, Pillar Two, minimum taxation, EU-D ...
12.07.2023 Ministry of Finance publishes draft bill on the implementati ... On Monday, 10 July 2023, the Federal Ministry of Finance sent the draft bill for the implementation of the Directive to ensure a global minimum level of taxation for multinational enterprise groups and large domestic groups in the Union (so-called Minimum Taxation Directive Implementation Act – “Implementation Bill”) to the associations with the request for comment by 21 July 2023. Categories: Tax & Legal News, LegislationKeywords: Pillar Two, minimum taxation, EU-Directi ...
28.12.2021 EU Commission proposes swift transposition of international ... On 22 December 2021, the European Commission proposed a draft directive to ensure effective minimum taxation of the worldwide activities of multinational corporations. Categories: From EuropeKeywords: minimum taxation, global corporate taxat ...
24.05.2019 German Finance Minister talks “minimum taxation” According to various statements of the German Finance Minister Olaf Scholz on 22 May 2019, a system of international minimum taxation will be discussed at the forthcoming G20 (June 2019) and G7 (August 2019) meetings. The aim is to agree such a system (within the terms of the Global Anti-Base Erosion "GloBE" agenda and given the name “BEPS 2.0”) with the other 128 states of the OECD in the Summer of 2020. Categories: Official PronouncementsKeywords: OECD, BEPS, minimum taxation, under-taxe ...
03.09.2014 Loss offset deferral unconstitutional? The Supreme Tax Court has referred to the Constitutional Court on whether a confiscatory effect of the loss offset deferral provisions can be a breach of the equal treatment requirement of the constitution. Categories: Supreme Tax Court casesKeywords: minimum taxation, loss offset
27.03.2013 First €1 m full loss offset for each period of assessment The Supreme Court has held that the initial full loss offset on €1 m applies to each period of assessment, rather than to each calendar year. Thus it can only be claimed once for a multi-year assessment. Categories: Supreme Tax Court casesKeywords: Liquidation, minimum taxation, loss offs ...
29.11.2012 “Minimum taxation” constitutional The Supreme Tax Court has held the “minimum taxation” deferral of loss relief to be constitutionally acceptable. Categories: Supreme Tax Court casesKeywords: Loss relief, minimum taxation, minimum t ...
25.05.2011 1999 minimum taxation rules do not affect loss carry-back to ... The Supreme Tax Court has held that the 1999 introduction of “minimum taxation” rules limiting loss offset by income type do not apply to a 1999 loss carried back to 1998. Categories: Supreme Tax Court casesKeywords: minimum taxation, loss offset, loss carr ...
25.05.2011 Loss offset limitation 1999-2003 only applies to notional lo ... The Supreme Tax Court has held that the 1999-2003 “minimum taxation” rules apply to “paper” losses, but not to those borne with true economic effect. Categories: Supreme Tax Court casesKeywords: minimum taxation, loss offset
