The Resource Concept of constructive contribution to capital : payment of salary of employee of German subsidiary by foreign parent company

Concept of constructive contribution to capital : payment of salary of employee of German subsidiary by foreign parent company

Label
Concept of constructive contribution to capital : payment of salary of employee of German subsidiary by foreign parent company
Title
Concept of constructive contribution to capital : payment of salary of employee of German subsidiary by foreign parent company
Creator
Subject
Summary
A case decided by the Supreme Tax Court of Germany concerned the corporate income tax liability of a German limited liability company owned by two Japanese companies that assigned several Japanese employees to work for the German subsidiary. The remuneration payable to the Japanese employees was paid , in part, in Japanese yen by the parent companies and the balance was paid by the German subsidiary. This note discusses the Court's decision in which it held, that the payments made by the Japanese companies/shareholders did not constitute constructive contributions to the capital of the German subsidiary
Citation source
In: European taxation. - Amsterdam. - Vol. 25 (1985),
http://library.link/vocab/creatorName
Killius, J
Language note
English
http://library.link/vocab/subjectName
  • case law
  • informal capital contribution
  • employment income
  • expatriate
Label
Concept of constructive contribution to capital : payment of salary of employee of German subsidiary by foreign parent company
Instantiates
Publication
Label
Concept of constructive contribution to capital : payment of salary of employee of German subsidiary by foreign parent company
Publication

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