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applicabledouble taxation convention provides for an exemptionof the branch profits in that country. Contrary to Marks& Spencer (C-446 …
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No doubt Christopher Columbus would have feltshortchanged if he knew the continent he discovereddoes not carry his name. In 1507, when the cartographerMartin Waldseemüller designed his famousworld map, he searched for a name for the Terra Nova(New World) and chose America, after the...
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participatein this game are small and midsize companies,which are subject to lifelong taxation on any assetthey purchase or develop …
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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
Many of our previous columns dealt with theframework and the aftermath of the major corporatetax reform (Unternehmenssteuerreformgesetz) in2008. The reform included a fundamental modificationof the German thin cap rule, or Zinsschranke (see TaxNotes Int’l, July 16, 2007, p. 263, Doc...
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, those who break it, and the ultimatequestion whether the government itself is infringing onthe law when buying stolen data. Moreover, it is aboutthe opinion of the vast majority...
Persistent link: https://www.econbiz.de/10009248910
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...
Persistent link: https://www.econbiz.de/10009248923