Retention period infringement under Section 6 (5) Sentence 6 ...
According to a decision of the Supreme Tax Court, where, within the framework of a multi-level partnership, an upper partnership, which indirectly participated in an asset transferred at book value under Section 6 (5) Sentence 3 Income Tax Act ("ITA"), changes its legal form into a corporation at book value, this will be considered an infringement of the retention period under Section 6 (5) Sentence 6 ITA
Categories: Supreme Tax Court cases
Keywords: transfer at book value, change of legal ...