Anyone who wants to open a company in Germany, or in fact any jurisdiction, has a lot to plan and organize in advance. In addition to a business plan with the business idea and an investment plan, discussions with a professional service
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A domestic corporation in Japan is taxed on its worldwide income, including foreign branch income. However, 95% of dividends received by a domestic corporation from a foreign company in which it has held at least 25% (or lower, depending on the relevant
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Germany taxes its corporate residents on their worldwide income. However, most double tax treaties (DTTs) exempt income attributable to a foreign permanent establishment (PE). Non-residents with PE or property income are taxed by assessment on German-source income; those earning royalties and dividends
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A resident company is subject to corporate income tax (CIT) in France on its French-source income. In that respect, income attributable to foreign business activity (if there is no treaty in force between France and the relevant foreign country) or to a foreign
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All undistributed corporate profits are tax exempt. This exemption covers both active (e.g. trading) and passive (e.g. dividends, interest, royalties) types of income. It also covers capital gains from the sale of all types of assets, including shares, securities, and immovable property.
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Corporate income tax (CIT) In general, the tax base for CIT purposes is determined on an accrual basis and consists of worldwide income less allowed deductions. The rules are equally applicable to companies and PEs. It is assumed that all income received
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HMRC issues its guidelines for compliance on what qualifies as R&D for tax purposes. The publication of HMRC’s latest guideline highlights the importance of correctly identifying whether a research and development (R&D) claim meets the necessary conditions to qualify for tax relief.
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Brief Summary From 1 January 2024 onward, investment tax credits will change in the following ways: Detailed Look On 19 December 2023, the Luxembourg Chamber of Deputies adopted a law to modernize the current investment tax credit; it will take effect 1
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The government has responded to the Treasury Committee’s call for a wholesale review of tax reliefs.
Shelf Company EU In the summer, a Treasury Committee report concluded that a “comprehensive and systematic” review of all tax reliefs is needed to identify opportunities for simplification. Responding to that report, the Financial Secretary to the Treasury (FST), Victoria Atkins, states that the
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