Global

Details

  • Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 8/6/2014

Germany - Excess transfers in tax groups, going-concern value write-downs 

August 6: The German federal tax court (BFH) and a lower court issued decisions concerning:
  • The treatment of excess transfers among members of tax groups, relating to a pre-tax group period
  • Write-downs of a lower going-concern value of loans to a foreign subsidiary
  • “Futile” expenses for setting up a fixed place of business (permanent establishment) in a third county, held not deductible in Germany if the exemption method applies

Read an August 2014 report prepared by the KPMG member firm in Germany: German Tax Monthly (August 2014)


Other topics discussed in this KPMG report concern:


  • e-Balance sheet – Publication of taxonomy version 5.3
  • Changes in the taxation of income of deemed commercial partnerships
  • FATCA implementation ordinance



©2014 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved.


The KPMG logo and name are trademarks of KPMG International.


KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever.


The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.


Direct comments, including requests for subscriptions, to us-kpmgwnt@kpmg.com.
For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at:

+ 1 202 533 4366

1801 K Street NW
Washington, DC 20006.

 

Share this

Share this

Subscribe

Subscribe to receive the latest TaxNewsFlash email alerts (you must select the option for TaxNewsFlash)


Already a Subscriber? Login


Not a member? Subscribe now