12.02.2018 Write-up of shares in GmbH not part of tax-neutral profit tr ... The Supreme Tax Court has decided that a gain arising from a share disposal can be rolled-over on a tax-neutral basis under Section 6b Income Tax Act where the privileged asset has been sold to a related entity. However, the Court also ruled that the part of the gain attributable to the write-up of the privileged asset – where the earlier write-down of the shares had reduced the taxable profits -could not be rolled over as a tax-neutral transfer under section 6b of the Income Tax Act. Categories: Supreme Tax Court casesKeywords: limited partnership, roll-over relief, I ...
16.04.2015 Roll-over relief provision infringes EU freedom of establish ... The ECJ has held the roll-over relief provisions allowing deferral of the tax charge on a capital gain from the sale of business property to infringe the freedom of establishment inasmuch as they require reinvestment of the gain in a replacement asset in Germany. Categories: From EuropeKeywords: capital gain, roll-over relief, business ...
