PwC

Tax & Legal

Tax & Legal

Final loss utilization by parent company in case of merger and liquidation of a second-tier subsidiary?


The European Court of Justice will have to decide once again on the justification of the non-deductibility of ‘final losses’ in the foreseeable future. In two Swedish cases the Advocate General has formulated her opinion and is not convinced of a “finality” or cross-border loss utilisation due to the particularities of the cases. Continue reading

Further relief from curtailment of loss utilization planned


The present curtailment of loss relief on changes of shareholders shall be modified to allow for a continued utilization of losses, provided the business operation does not change. The German government has taken the initiative and – for this purpose – agreed on a draft law. The respective draft was published on September 14, 2016. Continue reading