In the course of an Austrian tax audit related party transactions between C GmbH, Austria, and D AG (formerly A AG), Liechtenstein, could only be traced on the basis of balance sheets and tax returns of A AG, Liechtenstein. In January 2019, the Austrian Federal Ministry of Finance (BMF), Vienna, therefore submitted a request for […]
A Trust submitted a tax return for 2014 in which an asset loan to the C Trust in the amount of USD 5,393,695 (GBP 3,459,175) and a liability loan to the D Foundation in the amount of USD 7,715,134 (GBP 4,948,000) had been declared. Neither interest income nor interest expense was recognised or declared in […]
In this case a complaint was filed requesting that Legislative Decrees Nos. 762, 763 and 764, approved at the Plenary Session of the Legislative Assembly on 30-VIII-2014, which ended on 31-VII-2014, be declared unconstitutional on procedural grounds, for the alleged violation of art. 135 inc. 1 of the Constitution of the Republic. The fundamental reason […]
In the tax return for FY 2014, A c/o B AG declared a asset loans to related parties (holding company C) in the amount of USD 67,322,417.76 and liability loans to related parties (shareholder) in the amount of USD 110,051,410.39. Furthermore, interest income of USD 1,917,825.02 and interest expenses of USD 1,894,410.39 were declared in […]
A Const S.A. filed an appeal with the Central Administrative Court against a corrections made by the Tax Administration for FY 1990 under application of the arm’s length principle (contained in article 57 of the CIRC in Portugal). The Central Administrative Court dismissed the appeal. An appeal was then filed against this decision to the […]
ALP S.A. filed an appeal with the Central Administrative Court against a corrections made by the Tax Administration for FY 1992 under application of the arm’s length principle (contained in article 57 of the CIRC in Portugal). The Central Administrative Court dismissed the appeal. An appeal was then filed against this decision to the Supreme […]
On 17 February 2003, the President of the Polish Supreme Administrative Court and the Ombudsman requested the Constitutional Court to declare that Article 24b par. 1 of the Tax Ordinance of 29 August 1997 – by giving the tax authorities and fiscal control bodies, while resolving a tax case, the right to disregard the effects […]
