ECJ requested to interpret merger directive in context of German requirement for double rollover of book value
Article Abstract:
The European Court of Justice (ECJ) was requested by the Federal Tax Court of Germany to decide on whether the European Commission (EC) Merger Directive allows Germany for a deferred taxation on shares transaction exchange at the German shareholder level. The case of exchange of shares of an acquiring and a target company is discussed.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
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ECJ rules on Finnish intragroup transfers
Article Abstract:
Intragroup transfers between groups linked directly or indirectly by a 90% shareholding is allowed in the Finnish tax system as a tax deductible expense at the level of the transferor. Details on the European Court of Justice (ECJ) decision on the case of Oy AA, which does not have a Finnish permanent establishment, are presented.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
User Contributions:
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