Übersetzung für "Exemption method" in Deutsch

Applying the exemption method subjects EU businesses only to the tax framework of the foreign market.

Applying the exemption method also subjects EU businesses (only) to the tax framework of the foreign market.

Other types of specific anti-abuse provisions include switch-over from exemption to credit method in certain cross-border situations (where foreign source income has been subject to a low or preferential tax rate) and provisions explicitly targeted at passive investment in other countries.

Where the level of foreign tax is too low (tax rate below 10% or special regime), the exemption method is replaced by the imputation method.

This classification therefore reflects the predominant preference of the Member States for the credit or the exemption method in their Double Taxation Agreements.

This procedure avoids problems that might otherwise arise if the Home State and the Host State had agreed on different arrangements in their respective treaties with a third state, e.g. on the use of the credit method and the exemption method for certain income items.

The main principle for the taxation of residents (worldwide or territoriality) and how double taxation should be eliminated (credit or exemption method).

Unlike the exemption method, the imputation method therefore does not enable the benefit of the corporation tax reductions granted at an earlier stage to the company paying dividends to be passed on to the corporate shareholder.

In the United Kingdom, when a resident company received nationally-sourced dividends it was not liable to corporation tax in respect of those dividends (exemption method).

In its judgment delivered today, the Court recalls that EU law in principle permits a Member State to apply the exemption method to nationally-sourced dividends and the imputation method to foreign-sourced dividends.

It follows that application of the imputation method to foreign-sourced dividends as prescribed by the legislation at issue does not ensure a tax treatment equivalent to that resulting from application of the exemption method to nationally-sourced dividends, and therefore the UK legislation must be regarded as a restriction on freedom of establishment and on capital movements that is prohibited by the Treaty on the Functioning of the EU.

Based on a favorable tax regime, which is intended to attract non-resident citizens to Portugal by the application of the exemption method as the preferred method of elimination of international juridical double taxation.

Although interest income may well be taxable in the state of tax residency, and the convention prescribes the tax base exemption method for the other state involved, there are conventions where credit method needs to be applied.

This attraction is based on the application of the exemption method as the preferred method of elimination of international juridical double taxation of the foreign source and application of a special rate os 20% (mitigated and proportional taxation) to certain incomes.

These are generally known respectively as the "exemption" and "credit" methods.

The Court nevertheless observes that the exemption and imputation methods do not immediately cease to be equivalent as soon as exceptional cases exist in which nationally-sourced dividends are exempt although the profits out of which those dividends have been paid have not been subject in their entirety to an effective level of taxation corresponding to the nominal rate of tax.

Consequently, the restrictive interpretation of the patent exemption for diagnostic methods adopted by decision T 385/86 does not amount to setting a different standard for diagnostic methods than that established for methods of surgery or therapy, as has been asserted in decision T 964/99, point 3.6 of the Reasons.