17.03.2025 No deduction of foreign taxes for trade tax purposes within ... The Supreme Tax Court decided that the portfolio dividends received by the controlled company within a tax group from domestic and foreign corporations via an investment fund are subject to trade tax in full. A deduction of foreign withholding taxes in accordance with Section 34c (2) of the German Income Tax Act is not possible when determining the trade income tax basis of the tax consolidation group (Organschaft). Categories: Supreme Tax Court casesKeywords: foreign tax credit, trade tax group
25.04.2012 German trade tax restriction on interest deductibility uphel ... The Supreme Tax Court has upheld the German disallowance of one-half of the long-term interest expense for trade tax as not conflicting with the Interest and Royalties Directive and not infringing the German/Dutch tax treaty prohibition on discrimination. Categories: Supreme Tax Court casesKeywords: add-back, Inerest deduction, long-term i ...
