The Resource CJEU finds German exemption regime acceptable

CJEU finds German exemption regime acceptable

Label
CJEU finds German exemption regime acceptable
Title
CJEU finds German exemption regime acceptable
Title variation
German exemption regime found acceptable by the CJEU
Creator
Subject
Language
eng
Summary
This article reviews the Kronos judgment (C-47/12), in which The Court of Justice of the European Union held that Germany's tax exemption for cross-border dividends received by resident companies and its imputation credit for dividends received from German resident companies were within the boundaries of EU law. The Kronos case concerns German tax rules that eliminate or reduce the economic double taxation of dividends received by German resident companies by way of an exemption system when the dividends are received from companies resident outside Germany and by way of an imputation regime when the dividends were paid by German resident companies. Kronos International argued that such rules were incompatible with EU law. The Court of Justice of the European Union disagreed and explained that the imputation method and the exemption method related to situations that were not comparable from the perspective of a national rule designed to eliminate or reduce economic double taxation of dividends
Citation source
  • In: Tax notes international. - Falls Church. - Vol. 77 (2015),
  • In: Tax notes international. - Falls Church. - Vol. 78 (2015),
http://library.link/vocab/creatorName
O'Shea, T
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • ECJ case law
  • fundamental freedoms
  • cross-border dividend
  • double taxation relief
  • exemption method
  • imputation system
  • justification
Label
CJEU finds German exemption regime acceptable
Instantiates
Publication
Label
CJEU finds German exemption regime acceptable
Publication

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      52.37366609999999 4.9336932
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