Year-end adjustments and customs value
Within a multinational group, the prices for intercompany transactions often have to be adjusted retroactively in order to achieve an arm´s length-compliant result for the respective entities.
Within a multinational group, the prices for intercompany transactions often have to be adjusted retroactively in order to achieve an arm´s length-compliant result for the respective entities.
Real estate transfer tax (RETT) has become a major tax issue over the last year in any transaction and restructuring measure where real property is involved. Depending on the federal state, where the real estate is located, RETT can amount up to 6.5% of the purchase price or fair market value
In the “Hornbach-Baumarkt” case the European Court of Justice (EuGH) ruled on 31 May 2018 that Sec. 1 FTA was in principle compatible with EU law. However, the taxpayer should be granted the possibility to prove economical (non tax) reasons for deviations from the arm’s length principle.
In October 2017, the Commission presented the EU plans for a fundamental value added tax (VAT) reform within the EU. Now the EU ministers of finance agreed on further steps.
Following the judgments of the European Court of Justice the German Federal Fiscal Court admitted – as per judgment of 20th October 2016 - the retrospective correction of invoices regarding the deduction of input taxes under certain preconditions.
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Legislation on transfer prices is comparatively rare. However, when it occurs, it frequently concerns fundamental legal matters. A current decision of the European Court of Justice could cause a central standard of German foreign transaction tax law to alter.
The restructuring process at winch specialist BROEHL is now entering the next phase. After the company filed for insolvency, the first priority of the preliminary insolvency administrator, Dr. Ralf Bornemann, dhpg partner, was to successfully stabilise business operations.
In cross-border cases, the German tax authorities and foreign fiscal authorities can initiate an exchange of information on request, spontaneously or automatically, for the purpose of taxation procedures.
The foreign shareholder of a domestic corporation has the right to be refunded or exempted from withholding taxes on profit distributions when the requirements of a double taxation agreement or the EU parent-subsidiary directive are met.