The Resource Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method
Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method
Resource Information
The item Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- In a recent decision, Austria's highest court for tax litigation dealt with the treatment of losses of a foreign permanent establishment under a tax treaty which provides for the exemption method for avoiding double taxation. In its decision, which deviates considerably from the court's former rulings and indicates a new reasoning independent of EC law, the court concluded that a loss sustained by a foreign permanent establishment may be offset against the taxable profits of the head office in Austria. This article examines the court's decision and analyses its impact
- Language
- eng
- Label
- Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method
- Title
- Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method
- Language
- eng
- Summary
- In a recent decision, Austria's highest court for tax litigation dealt with the treatment of losses of a foreign permanent establishment under a tax treaty which provides for the exemption method for avoiding double taxation. In its decision, which deviates considerably from the court's former rulings and indicates a new reasoning independent of EC law, the court concluded that a loss sustained by a foreign permanent establishment may be offset against the taxable profits of the head office in Austria. This article examines the court's decision and analyses its impact
- Citation source
- In: Bulletin for international fiscal documentation. - Amsterdam. - Vol. 56 (2002),
- http://library.link/vocab/creatorName
-
- Gahleitner, G
- Nowotny, C. (Clemens)
- Geographic coverage
- European Union
- Language note
- English
- http://library.link/vocab/subjectName
-
- PE
- exemption method
- losses
- case law
- Label
- Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method
- Label
- Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Austrian-court-rules-on-the-treatment-of/CbKYc0iQB0o/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Austrian-court-rules-on-the-treatment-of/CbKYc0iQB0o/">Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Austrian-court-rules-on-the-treatment-of/CbKYc0iQB0o/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Austrian-court-rules-on-the-treatment-of/CbKYc0iQB0o/">Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
