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CJEU Holds Germany May Disallow Deduction of Final Losses of a German Company's PE Where the PE's Profits are Exempt Under a Tax Treaty

|Approved Changes|Germany-European Union
Germany-European Union

On 22 September 2022, the Court of Justice of the European Union (CJEU) issued its judgment on whether the German tax authority's refusal to take into account the final losses of a taxpayer's permanent establishment in another EU Member State violated the freedom of establishment. The tax authority refused to take into account the final losses because the profits of the establishment were exem…

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