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Many European companies are attracted to Maltabecause of its full imputation system, more commonlyknown as the international holding company regime.In fact, a vast majority of German blue chips run aMalta holding or finance company.[...]
Persistent link: https://www.econbiz.de/10009248906
The Latin principle pacta sunt servanda (‘‘agreementsmust be kept’’) serves as a cornerstone of socialinteraction, peace, and justice. If a breach of contractdid not have some sort of ramification, the motivationto stick to the stipulations of the treaty would decreasegreatly, the...
Persistent link: https://www.econbiz.de/10009248907
If German tax law was a river flowing over all businesstransactions and commercial accounting, thelast words of Norman … Maclean in A River Runs ThroughIt best suit the traditional relationship between commercialand tax accounting. For more than … 100 yearsthe principle of strict book-tax conformity (or the authoritativeprinciple, or Maβgeblichkeitsprinzip) was …
Persistent link: https://www.econbiz.de/10009248908
’l, July 16, 2007, p. 263, Doc 2007-15373, or2007 WTD 141-9), and the change-of-ownership rule, orMantelkauf (see Tax Notes Int …
Persistent link: https://www.econbiz.de/10009248909
The tax issue causing uproar in Germany and Switzerlandhas all the ingredients for a good story. Itis about tax law … German tax evaders who used Swissbanks as a way to escape from their tax liabilities?[...] …
Persistent link: https://www.econbiz.de/10009248910
(Sondervergütungen) now codified in section50d paragraph 10 of the Income Tax Act (Einkommensteuergesetz,or EStG). The question iswhether …
Persistent link: https://www.econbiz.de/10009248922
The fight against tax havens has caused some majordistortions in the relationship between Germanyand Switzerland …. Similar to the approach used in theUnited States in the Stop Tax Haven Abuse Act, Germanyintensified its measures to prevent … tax evasion byits own citizens starting with a German intelligenceagency’s purchase of data on Liechtenstein bank accounts …
Persistent link: https://www.econbiz.de/10009248923
It was a close call, but eventually the German legislativebody managed to save the Inheritance andGift Tax Act … (Erbschafts- und Schenkungssteuergesetz)from being automatically abolished. In fact, abolishingthe inheritance tax is not an … uncommon measure inCentral Europe. As of August 1, 2008, Austria nolonger enforces inheritance tax, because the …
Persistent link: https://www.econbiz.de/10009248924
International tax law is going through a period ofremarkable change. Trends come and go frequently;however, three …
Persistent link: https://www.econbiz.de/10009248927
In this article, we use the expression ‘‘holding haven’’to describe a tax jurisdiction with a very attractivelegal … framework for holding companies. Holdinghaven regimes are more sophisticated thanconventional tax haven regimes, demanding more …
Persistent link: https://www.econbiz.de/10009248928