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

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
Creator
Subject
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
Instantiates
Publication
Label
Austrian court rules on the treatment of cross-border losses under tax treaties with exemption method
Publication

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      52.37366609999999 4.9336932
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