Doppelte Verlustberücksichtigung bei Organschaft Buchkatalog

»Dual Loss Consolidation and German Corporate Tax Groups« The thesis focusses on the German Corporate Tax Act's dual consolidated loss rule. Although the provision only applies to corporate tax groups, its wording suggests a rather broad scope. Against this background, potential scenarios and aspects of foreign tax laws such as the dual consolidated loss rule figuring in section 1503(d) of the US Internal Revenue Code are discussed. The analysis encompasses the OECD's report on BEPS Action 2 as well as the Council Directive (EU) 2017/952.