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DMC v Finanzamt Hamburg-Mitte (Judgment of The Court): ECJ 23 Jan 2014

Taxation – Corporation tax – Transfer of an interest in a partnership to a capital company – Book value – Value as part of a going concern – Agreement on the prevention of double taxation – Immediate taxation of unrealised capital gains – Different treatment – Restriction on free movement of capital – Preserving the balanced allocation of powers to impose taxes between the Member States – Proportionality

C-164/12, [2014] EUECJ C-164/12, [2014] BTC 16, [2014] 2 CMLR 47, ECLI:EU:C:2014:20, [2014] STC 1345
Bailii

European, Corporation Tax

Updated: 29 November 2021; Ref: scu.520796

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