mismatch outcome” means a double deduction or a deduction without inclusion;
In cases of a deduction without inclusion, the Member State of the payer shall deny the deduction of such payment.
Those mismatch outcomes may lead to a double deduction or a deduction without inclusion, and should therefore be eliminated.
Those mismatch outcomes may lead to a double deduction or a deduction without inclusion, and should therefore be eliminated.
Those mismatch outcomes could lead to non-taxation without inclusion, a double deduction or a deduction without inclusion, and should therefore be eliminated.
a payment under a financial instrument gives rise to a deduction without inclusion outcome and:
The Luxembourg bill also clarifies that payments to a tax-exempt entity under either a hybrid instrument or a hybrid entity, do not give rise to a deduction without inclusion outcome.
In case of a deduction without inclusion, the member state of the payer should deny the deduction of such payment.
a hybrid entity mismatch involving a third country leading to a deduction without an inclusion;
In cases of a deduction without inclusion, the Member State of the payer shall deny the deduction of such payment.
(b) a deduction of a payment from the taxable base in the jurisdiction in which the payment has its source without a corresponding inclusion for tax purposes of the same payment in the other jurisdiction ('deduction without inclusion');
In case of a deduction without inclusion the same rules should apply as for neutralising a hybrid financial instrument or hybrid entity mismatch leading to a deduction without inclusion.
there is a deduction of a payment in the Member State in which the payment has its source without a corresponding inclusion for tax purposes of the same payment in the other Member State (‘deduction without inclusion’).
(b) a deduction of a payment from the taxable base in the jurisdiction in which the payment has its source without a corresponding inclusion for tax purposes of the same payment in the other jurisdiction ('deduction without inclusion');
there is a deduction of a payment in the Member State in which the payment has its source without a corresponding inclusion for tax purposes of the same payment in the other Member State (‘deduction without inclusion’).
To the extent that a hybrid mismatch results in a deduction without inclusion, the deduction shall be denied in the Member State that is the payer jurisdiction of such payment.
When a hybrid mismatch results in a deduction without inclusion, the deduction shall be denied in the payer jurisdiction.
To the extent that a hybrid mismatch results in a deduction without inclusion, the deduction will be denied in the payer’s member state.
To the extent that a hybrid mismatch between Member States results in a deduction without inclusion, the Member State of the payer shall deny the deduction of such payment.
(b) there is a deduction of a payment in the Member State or third country in which the payment has its source without a corresponding inclusion of the same payment in the other Member State or third country ('deduction without inclusion').
a hybrid entity mismatch involving a third country leading to a deduction without an inclusion;
To the extent that a hybrid mismatch that involves a third country results in a deduction without inclusion:
Requêtes fréquentes français :1-200, -1k, -2k, -3k, -4k, -5k, -7k, -10k, -20k, -40k, -100k, -200k, -500k, -1000k,
Requêtes fréquentes anglais :1-200, -1k, -2k, -3k, -4k, -5k, -7k, -10k, -20k, -40k, -100k, -200k, -500k, -1000k,
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