Übersetzung für "Verlustverrechnung" in Englisch

No restrictions as to the amount of tax losses apply.

The advantage of this approach over the Commission proposal lies in the greater symmetry between the taxation of profits and the offset of losses.

The focus of the book is the loss offsetting rules relevant for permanent establishments and in the corporate group.

It is an open secret that companies regularly use cross-border loss relief to reduce their tax bill by moving their profits to low-tax zones and low-tax countries.

Provided that taxation competition does not exist on equal terms and there is no minimum requisite agreement on a common, unified tax base for companies so as to put in place uniform, transparent rules for measuring the tax base, the provision of opportunities such as this regarding tax relief for losses of a cross-border nature at present demands that we adopt a cautious approach.

In the legislation meant to implement the Marks Spencer ruling, the United Kingdom imposes conditions on cross border group relief which make it virtually impossible for tax payers to benefit from the relief.

This is because the corporate tax law does not generally allow for losses to be offset when there has been a significant change in the ownership structure, giving a clear financial advantage to ailing firms and possibly their acquirers.

Only by making consolidation possible can the following benefits be obtained: crossborder loss relief, avoidance of the current problems with transfer pricing, the ability to carry out EU-wide tax-neutral restructuring, the avoidance of double taxation, and equal treatment of EU subsidiaries and EU permanent establishments.

Recognizing the need for greater international competitivity on the part of European firms, the Committee opinion supports the measures allowing them to carry forward their losses but with a time-limit.

There are other restrictions on the offsetting of losses, for example, in the case of negative income from investment in a loss-making model or losses from commercial stock-breeding or stock-keeping.

Recent changes in tax rules for carrying forward losses will especially benefit young and innovative companies, as will the top-ups of various project funding programmes.

In particular, the author analyzes why the principles of this decision may not generally be applied to cross-border tax utilization of losses and to what extent a change of the case-law has occurred in the context of direct taxation.

Furthermore, he was concerned with questions of the offsetting of losses relating to different sources of income, but also worked on the project he began in 2008 on the success rate of proceedings in fiscal courts in Germany.

The first is a reform of the tax rules for carrying forward losses, which will make it easier for companies with innovative business models to grow.

Moreover, we have performed an evaluation whether any limitations in the use of tax losses or expiry dates for the usage of tax losses have been incorporated in the calculation.

Possible tax instruments are the liberation of investors from capital gains tax, a way to assign start-up losses and set off against other income, as well as an opportunity for immediate loss account.

Loss Utilization for Tax Purposes According to EC Law. Treating cross-border situations different than those in a purely domestic context often violates the fundamental EU freedoms. Whether this also applies with respect to tax law limitations applicable to cross-border loss utilization is the subject of this book of Christian Wimpissinger published by the publishing house Peter Lang.

Variation margin (i.e. daily settlement of profits and losses) as well as premiums on traditional options and futures on options must be paid in cash. Modern risk management methods need to cope with the advances in trading speeds and changing market characteristics.