Loss utilisation restriction (Section 2a (1) Sentence 1 No. ...
According to a decision of the Supreme Tax Court published on 21 October 2021, the loss of a silent partner's contribution, which is reflected as a partial write-down for tax purposes, does not fall within the scope of the loss utilisation restriction under Section 2a (1) Sentence 1 No. 5 in conjunction with Sentence 2 Income Tax Act (ITA).
Categories: Tax Court
Keywords: investment write-down, silent partnershi ...