Traduction de «déduction d'impôt » (Français → Anglais) :

However, in the case of Germany, for example, insurance tax is a transaction tax and is therefore not comparable to a tax on income. Insurance tax (‘Versicherungsteuer’) should therefore be deductible.

2. By way of derogation from paragraph 1, where the Member State of the transferring company applies a system of taxing worldwide profits, that Member State shall have the right to tax any profits or capital gains of the permanent establishment resulting from the merger, division, partial division or transfer of assets, on condition that it gives relief for the tax that, but for the provisions of this Directive, would have been charged on those profits or capital gains in the Member State in which that permanent establishment is situated, in the same way and in the same amount as it would have done if that tax had actually been charged a ...[+++]nd paid.

2. A Member State exercising the right referred to in paragraph 1 shall give relief for the tax which, but for the provisions of this Directive, would have been charged on the fiscally transparent company on its income, profits or capital gains, in the same way and in the same amount as that Member State would have done if that tax had actually been charged and paid.

the competent institution shall take into account the amount of benefits to be paid by another Member State before deduction of tax, social security contributions and other individual levies or deductions, unless the legislation it applies provides for the application of rules to prevent overlapping after such deductions, under the conditions and the procedures laid down in the Implementing Regulation;

The question states that the effect of the amended version of the second and third sentences of Section 20(1)(3) of the ITA in conjunction with Article XXIII(5) of the Structural Adjustment Act (Federal Gazette 297/1995) was to make only half the cost of business entertainment deductible.

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.