Voorbeelden van het gebruik van Distributed profits in het Engels en hun vertalingen in het Nederlands
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the parent company shall deduct from the tax on the distributed profits which it receives from its direct subsidiary that fraction of the tax paid not only by this direct subsidiary
where it is equal to 58.6% and 100% respectively of the aggregate amount of tax charged on distributed profits.
The part of the 5% charge applying to the tax credit to which distribution of the dividend confers entitlement does not possess the characteristics of a withholding tax on distributed profits, in principle prohibited by Article 5(1) of the Directive, because it is not imposed on the profits distributed by the subsidiary.
the judgment in Océ Van der Grinten dealt with a tax levied on a tax credit which did not possess the characteristics of a withholding tax on distributed profits see Océ Van der Grinten, paragraph 55.
is fixed at 5% of distributed profits, including tax credits.
Where the entity distributes profits to the taxpayer out of income previously included in the tax base of the taxpayer pursuant to Article 59 and the taxpayer is liable to tax on these distributed profits, the amounts of income previously included in the tax base pursuant to Article 59 shall be deducted from that tax base when calculating the taxpayer's liability to tax on the distributed profits. .
Article(7) of Directive 90/434/EEC provides for the exemption of these capital gains since these profits may be derived just as easily in the form of distributed profits from the transferring company that would have been exempted under Council Directive 90/435/EEC of 23 July 1990 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States23.
On the question of the distribution of powers between the Member State of the source of the distributed profits and the Member State of residence of the parent company with regard to the prevention of economic double taxation,
The addback to the taxable income of a parent company established in France of 5% of the tax credits attributed upon the distribution of profits by a subsidiary established in another Member State… where those distributed profits have been subject in that other State to a withholding tax,
As far as corporation tax is concerned any(economic) double taxation of distributed profits is to be avoided by the State of the parent company,
Both courts have ruled that the distributed profit according to French law constitutes immoveable income.
Dividends and distributed profit 2.1.1.2.
In the EESC's view, national accreditation bodies should operate like non-profit bodies in the sense that they must not distribute profits, as established internationally in ISO/IEC 1701129.
logical system for distributing profits between the Member States and consequently between countries with different tax rates.
With regard to the subsidiary, it is clear that its overall tax charge under the KStG 1996 does not differ according to whether it distributes profits to a resident or a nonresident parent company.
As a consequence, under the classical system the company's profit is subject to corporation tax at the company level and the distributed profit, i.e. the dividend,
Where a parent company receives distributed profits other than when its subsidiary is liquidated,
Where the entity distributes profits to the taxpayer, the amounts of income previously included in the tax base pursuant to Article 8 shall be deducted from the tax base when calculating the amount of tax due on the distributed profits, in order to ensure there is no double taxation.
of the Directive obliges the Member State of the parent company to exempt distributed profits from the subsidiary or to authorise the parent company to deduct that fraction of the corporation tax paid by the subsidiary which relates to those profits. .
With respect to the concept of distributed profits, that provision makes no distinction between cases where the State is subject to the requirement to provide for the set-off of the withholding tax charged in the Member State of the subsidiary and cases where it is not subject to such a requirement.