12.03.2019 ECJ: Passive income attribution from controlled companies re ... The European Court of Justice has held that the German provision for the taxation of controlled company income from invested capital from outside the EU might fall under the “grandfather” clause of Art 64 TFEU, provided the German legislation has remained substantially unchanged since that date. It is now for the Supreme Tax Court to decide finally whether this is the case. Categories: European Court of JusticeKeywords: standstill clause, foreign passive incom ...
31.01.2018 German taxation of dividends paid to Canadian pension fund i ... The Lower Tax Court of Munich referred preliminary questions to the European Court of Justice regarding the compatibility of the German regime of dividend withholding tax imposed on a Canadian pension fund with the free movement of capital as provided in Article 63 of the Treaty on the Functioning of the European Union. Categories: European Court of JusticeKeywords: pension fund, dividend withholding tax, ...
