Nilfisk Premium 190-12 Brand, Multi-Colour

Product Information

Taxation of dividends and other income constituting participation in the profits of legal persons whose registered office is situated in … the Republic of Poland is set at 19% of income received, subject to paragraph 2. That request was rejected by a decision of 2 May 2011, on the ground that, as an investment fund established in the United States of America, the applicant in the main proceedings did not satisfy the exemption conditions set out in Article 6(1)(10) of the law on corporation tax. On the assumption that that examination should be undertaken with regard to the principle of free movement of capital, the referring court raises the question of whether the legislation at issue in the main proceedings involves a restriction on that freedom which is not justified.

and 2021 (Table 3.1) to 1.24 million hectares. Table 3.1 Total area of rented land under FBT agreements in England by farm type (thousand ha) (a)(b)(c) Type In that regard, it is common ground that the only distinguishing criterion established by the tax legislation at issue in the main proceedings is based on the place of residence of the investment fund, since only investment funds established in Poland can qualify for the exemption from deduction of tax at source on dividends which they receive. The tax exemption enjoyed by resident investment funds is not conditional on their unit-holders being taxed on the income distributed to them. If a national or local policy identifies a frequency expectation, a claim for a test that exceeds that expectation may be denied as The proponent of this regulation is the Deputy Chief of Staff for Operations and Plans (DCSOPS). The DCSOPS has the authority • to approve exceptions to this regulation that are consistent with control­ling law and regulation. The DCSOPS may delegate this authority in writing to a division chief within the proponent agency in the grade of colonel or the ci­vilian equivalent. In that regard, the Polish and German Governments argued, in their observations and at the hearing, that, first the provision of national law at issue in the main proceedings, which provides for the taxation of dividends paid by Polish companies to non-resident investment funds, was already in force before 31 December 1993, the rules relating to that taxation not being subsequently altered, and that, secondly, since that taxation applied indiscriminately, without regard to the number of shares owned in the Polish companies, the movements of capital at issue in the main proceedings may also fall within the scope of the concept of ‘direct investment’, as explained in the Court’s case-law. In any event, the restriction at issue involved the provision of financial services.However, for an argument based on such a justification to succeed, a direct link must be established, according to settled case‑law, between the tax advantage concerned and the compensating of that advantage by a particular tax levy, with the direct nature of that link falling to be examined in the light of the objective pursued by the rules in question ( Santander Asset Management SGIIC and Others, paragraph 51 and case-law cited).

a) The breaks in the series shown in 2012 and 2017 represent changes in the method used to assign farms to a specific farm type. Where breaks occur, the number of agreements has been calculated using both methods for comparability. This release provides estimates of average annual rent per hectare paid under Full Agricultural Tenancies, Farm Business Tenancies, seasonal agreements and informal agreements for the average period 1st March 2021 to 28th February 2022, together with the area of land covered by these agreements. Key words

Get email updates

First, as regards the allocation of the power to tax, the German Government submits that the case-law concerning that ground for justification must be applied solely to situations internal to the European Union, since, in cases of movements of capital to and from non-Member countries, the persons concerned may not rely on the rules of the internal market, since a restriction on the fiscal sovereignty of a Member State by the effect of the free movement of capital would have as a direct consequence a transfer of the tax base to a non-Member country.