Notional income from the cross-border international transfer of assets - why the amendments to the German Income Tax Act violate the freedom of establishment
Article Abstract:
The German Income Tax Act was amended to include taxation of cross-border transactions regarded as a danger to the German tax. Businesses which accrued gains are taxed without realizing profits whenever assets are transferred outside the German tax net. Tax liability for unrealized profits and amendments to the income tax law are discussed.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2008
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The European Court of Justice on the Dutch Levy upon emigration of a substantial participation holder in a corporation
Article Abstract:
The European Court of Justice ruled that the Dutch law disposing shares upon emigration of a substantial participation holder does not infringe European law provided that some conditions were met. The levy has been in place in the Netherlands since 1997.
Publication Name: Intertax
Subject: Law
ISSN: 0165-2826
Year: 2007
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