Traduction de «Impôt anticipé sur les sociétés » (Français → Anglais) :

first, that provision permits the grant of a tax credit, the notional withholding tax, to the recipients of income from debt-claims or loans granted to a coordination centre, within the meaning of Royal Decree No 187 of 30 December 1982 on the creation of coordination centres, when the company which uses the funds borrowed by or through the coordination centre in order to acquire a tangible asset which it uses in Belgium in the exercise of its business activity, confers the right to use that asset on a company which forms part of the same group of companies and which is resident in Belgium, whereas, second, that provision does not permit ...[+++] the grant of a tax credit when the same company confers a right to use the same tangible asset on a company which also forms part of the same group of companies but which is resident in a Member State other than Belgium?

Its objective is also to increase the German corporate tax base and to offset the reduction in the corporate income tax rate from 25 % to 15 %.

1. The term ‘withholding tax’ as used in this Directive shall not cover an advance payment or prepayment (précompte) of corporation tax to the Member State of the subsidiary which is made in connection with a distribution of profits to its parent company.

try to achieve an agreement on a common corporate tax base for businesses operating in several Member States with different tax rules.

The Directive also provides for the tax to be offset by the parent company to be determined in such a way (including the taxes paid by lower-tier subsidiaries) as to totally eliminate double taxation.

The Directive also provides for the tax to be offset by the parent company to be determined in such a way (including the taxes paid by lower-tier subsidiaries) as to totally eliminate double taxation.