13.09.2022 Liability of the Controlled Company arising after the termin ... In a recent case, the Supreme Tax Court decided that the liability of a controlled company (subsidiary) in a tax consolidation group (“Organschaft”) for the tax liability of its controlling company (parent in the Organschaft) is not necessarily limited to such taxes which arose during the existence of the Organschaft. The controlled company may be liable to the extent that the parent is required to pay tax on the controlled company’s turnover and may deduct input tax amounts from invoices for services obtained by the controlled company. Categories: Supreme Tax Court casesKeywords: VAT group, secondary liability, tax cons ...
28.03.2022 Compliance-Trap in International Insurance Programs We have been noticing an increased number of notifications to the Federal Central Tax Office during tax audits for the failure by German subsidiaries and permanent establishments to declare and pay over German Insurance Premium tax on premiums paid by a foreign group entity to an insurer domiciled outside the EU or EEA. This can prove very costly. Categories: Tax & Legal NewsflashKeywords: secondary liability, tax audit, insuranc ...
13.04.2011 Acquirer can appeal against seller’s taxes for which he is l ... The Supreme Tax Court has held that an acquirer of a business may appeal against the otherwise final tax obligations of the seller for which he has become liable through the takeover. Categories: Supreme Tax Court casesKeywords: seller's taxes, acquirer, secondary liab ...
