Rechtsfragen einer "Dual Consolidated Loss"-Regelung de lege lata und de lege ferenda
Am Beispiel des § 14 Abs. 1 S. 1 Nr. 5 KStG
Nomos, 1. Edition 2020, 344 Pages
The product is part of the series
Schriften des Interdisziplinären Zentrums für Internationales Finanz- und Steuerwesen – International Tax Institute – der Universität Hamburg
Description
This book addresses various topics in relation to cross boarder dual consolidated loss. Also the German dual consolidated loss rule (§ 14 I 1 lit. 5 KStG) is viewed and a detailed comparison to the United States dual consolidated loss rule is made.
Furthermore the legal specifications related to a limitation of loss offsetting from the view of constitutional law and European law are descripted as well as a concrete proposal for a new law is developed.
Finally this work contains thoughts related to a “fair” allocation of losses between the involved states in the case of limited as well as unlimited tax liability.
Furthermore the legal specifications related to a limitation of loss offsetting from the view of constitutional law and European law are descripted as well as a concrete proposal for a new law is developed.
Finally this work contains thoughts related to a “fair” allocation of losses between the involved states in the case of limited as well as unlimited tax liability.
Bibliographical data
| Edition | 1 |
|---|---|
| ISBN | 978-3-8487-6754-0 |
| Subtitle | Am Beispiel des § 14 Abs. 1 S. 1 Nr. 5 KStG |
| Publication Date | Jul 8, 2020 |
| Year of Publication | 2020 |
| Publisher | Nomos |
| Format | Softcover |
| Languages | deutsch |
| Pages | 344 |
| Medium | Book |
| Product Type | Scientific literature |
Additional material
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