Special Report on
German Thin Capitalisation Rules
German Thin Capitalisation Rules - Trends
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It has long been the goal of the EU Commission to introduce rules allowing cross border loss relief in group situations. Indeed, in 1990 the EU Commission put forward proposals, which were withdrawn due to lack of agreement amongst the Member States. However, allowing domestic intra group loss relief whilst restricting the operation of such relief cross border within the EU runs the obvious risk of contravening fundamental freedoms, such as the freedom of establishment. In recent years, the European Court of Justice (ECJ) has been asked to consider a number of such restrictions and has released a series of decisions accepting ...
The following post includes some draft notes on a future comment on the recently released OECD paper on Art. 24 of the OECD Model. I will be away for some days but feel free to leave your comment. The non-discrimination article, which is designed to prohibit discriminatory taxes levied against foreign nationals or their businesses, appears in almost every tax treaty. But the principles and practice have not always been aligned. It appears that there is some reluctance and uncertainty as regards the acceptability and application of the nondiscrimination concept by tax authorities and ... Read More
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GERMAN THIN CAPITALISATION RULES
John Stadtmiller - May 18 2010- Robby Noel, Bob Chapman- Roundtable
The Dollar: Where's It Headed? [Joseph T. Salerno]
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