liability method of tax allocation oor Spaans
liability method of tax allocation
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The Commission concludes under both lines of reasoning that the profit allocation methods endorsed by the contested tax rulings result in a lowering of ASI's and AOE's corporation tax liability under the ordinary rules of taxation of corporate profit in Ireland as compared to non-integrated companies whose taxable profit reflects prices determined on the market negotiated at arm's length.
Ahora pide lo que quieras, cariñoeurlex-diff-2017 eurlex-diff-2017
Consequently, Irish Revenue's acceptance of the profit allocation methods premised on that choice lowers ASI's and AOE's annual Irish corporation tax liability as compared to non-integrated companies whose taxable profit reflects prices determined on the market negotiated at arm's length.
Hola.- Hola, reinaeurlex-diff-2017 eurlex-diff-2017
The contested tax rulings endorse methods for allocating the profit of ASI and of AOE to their respective Irish branches, which allow those companies to determine their taxable profit and thus their corporation tax liability in Ireland on a yearly basis for the period during which those rulings were in force.
Si el discurso de Kennedy se pasa de las #: #, no veré el programa de Lucy, de Danny Thomas ni el de Andy Griffith, y eso no me va a gustareurlex-diff-2017 eurlex-diff-2017
This is because ADI had originally calculated its corporation tax liability by applying the profit allocation methods endorsed in the 2007 tax ruling, since that ruling included a ‘restructuring clause’ (101) whereby that profit allocation method would also apply to a new subsidiary in the event of a restructuring of Apple's corporate structure in Ireland.
¡ Estudio por las noches!eurlex-diff-2018-06-20 eurlex-diff-2018-06-20
In other words, Apple seems to have taken, as a starting point, the overall accounting profit of ASI as the taxable base for the purposes of calculating its corporation tax liability in Ireland, applied the profit allocation methods endorsed by the contested tax rulings as a means to reduce that base, and accepted that ASI's Irish corporate incomes tax liability was lower than that generally applied to companies subject to tax in Ireland (199).
Este ensayo se utilizará para determinar si una lámpara de incandescencia cumple los requisitos, mediante la comprobación de la correcta posición de los filamentos en relación con el eje de referencia y el plano de referenciaeurlex-diff-2018-06-20 eurlex-diff-2018-06-20
Since those profit allocation methods lower ASI's and AOE's tax liability under the ordinary rules of taxation of corporate profit in Ireland as compared to non-integrated companies whose taxable profit under that system is determined by prices negotiated at arm's length on the market, the contested tax rulings, by endorsing those methods, confer a selective advantage on ASI and AOE for the purposes of Article 107(1) of the Treaty.
Vas a hacer que te demandeeurlex-diff-2018-06-20 eurlex-diff-2018-06-20
By a subsidiary line of reasoning, the Commission concludes that the SMBV APA, by endorsing under the Decree, based on Article 8b(1) CIT, a method for arriving at a profit allocation to SMBV that cannot be considered to result in a reliable approximation of a market-based outcome in line with the arm's-length principle and that results in a lowering of SMBV's tax liability as compared to other group companies taxable in the Netherlands, confers a selective advantage on SMBV for the purposes of Article 107(1) of the Treaty.
Me alegro de que te haya inspiradoeurlex-diff-2017 eurlex-diff-2017
The Commission concludes that the SMBV APA, by endorsing a method for arriving at a profit allocation to SMBV within the Starbucks group that cannot be considered to result in a reliable approximation of a market-based outcome in line with the arm's-length principle and that results in a lowering of SMBV's tax liability under the general Dutch corporate income tax system as compared to non-integrated companies whose taxable profit under that system is determined by the market, confers a selective advantage on SMBV for the purposes of Article 107(1) of the Treaty.
Pas-Pisueñaeurlex-diff-2018-06-20 eurlex-diff-2018-06-20
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