The Supreme Tax Court has held that a sale of shareholdings within a group was not sufficiently good cause for breaking an unwanted German tax group before its expiry date. Continue reading
Tax & Legal
A partial compromise was reached by a mediation committee of the two chambers of Parliament leading to a modified Bill for the Revision and Simplification of Corporate Taxation and of the Tax Law on Travel Cost and to acceptance of a modest increase in the basic personal allowance for income tax. The Bundestag has now passed both bills and forwarded them to the Bundesrat for confirmation at its next session, due to be held on February 1, 2013. Continue reading
The Supreme Tax Court has held that a profit pooling agreement must run for five full years, i.e. 60 months, for tax recognition.
The Supreme Tax Court has held that there is no serious doubt that a profit pooling agreement must provide for a ten year statute bar on loss subvention claims of an Organschaft subsidiary.
The Supreme Tax Court has rejected an Organschaft as the profit pooling agreement was not properly implemented when the annual profit was surrendered without covering losses brought forward.