01.07.2022 Income adjustment pursuant to Section 1 (1) FTA vis-à-vis a ... Following a referral from the Federal Constitutional Court, the Supreme Tax Court has again had to rule on the income adjustment pursuant to Section 1 (1) Foreign Taxes Act vis-à-vis the write-down of an unsecured loan receivable issued within a group Categories: Supreme Tax Court cases, Constitutional ...Keywords: income adjustment, International Tax, un ...
09.04.2021 Successful constitutional complaint against income correctio ... The German Constitutional Court overturned a 2019 judgment of the Supreme Tax Court regarding the erstwhile change in its case law on the issue of the income correction with respect to an unsecured group loan because the tax court failed to submit the facts of the case to the European Court of Justice (ECJ) for final clarification and thus violated the complainant's right to the lawful judge under Article 101(1) of the Constitutional Statute. Categories: Constitutional CourtKeywords: allocation of taxing rights, income corr ...
