Orbitax

Germany Tax News

International tax conference on CCCTB held in Berlin

18 June 2007

Federal Ministry of Finance issues guidance on anti-treaty-shopping rules

18 June 2007

Indian decision that income arising from dealings with an Indian branch is taxable

18 June 2007

Discussion draft on application and interpretation of non-discrimination article of OECD Model – details

18 June 2007

Revised Commentary on Article 7 of OECD Model released

28 May 2007

ECJ

28 May 2007

ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details

28 April 2007

Federal Cabinet adopts Draft Bill on corporate tax reform

28 April 2007

Federal Ministry of Finance issues Draft Bill on corporate tax reform

24 March 2007

Final Report on Improving the Resolution of Tax Treaty Disputes

24 March 2007

Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement

24 March 2007

ECJ: hearing in case regarding Dutch withholding tax on outbound dividends

24 March 2007

Federal Ministry of Finances clarifies application of CFC rules

24 February 2007

EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies

24 February 2007

EU Commission requests Italy to implement the Interest and Royalties Directive correctly

24 February 2007

Report on Attribution of Profits to PEs released

24 February 2007

EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends

24 February 2007

Treaty between Germany and Belgium - Mutual agreement concerning treatment of severance payments

24 February 2007

Treaty between Singapore and Germany enters into force

15 January 2007

ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details

15 January 2007

Annual Tax Act 2007 and Bill on implementation of European company approved by Federal Council

15 January 2007

ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment

15 January 2007

Federal tax authority publishes guidance on APAs

17 December 2006

Revised proposal on corporate tax reform

17 December 2006

German Federal Tax Court holds CFC rules not applicable in cases of administratively limited tax relief in order to comply with low taxation threshold

17 December 2006

On 23 August 2006, the Federal Cabinet approved the Annual Tax Act 2007. The newly included Sec. 20(2b) Income Tax Act, which extends the restriction on loss set-offs from tax deferral schemes, shall already apply for the tax year 2006. To become effective, the Bill has to be passed by the Federal Council as well.

14 October 2006

Plans to reform corporate taxation – Federal Cabinet agrees on general framework

12 September 2006

Proposed reform concerning cross-border mergers – Bill approved

12 September 2006

European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

13 August 2006

US Senate may hold hearings on new Denmark, Finland, and Germany protocols

13 August 2006

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