a the assessment and collection of tax, and the recovery and enforcement of tax claims, and

b) in respect of other taxes, for taxes chargeable for any tax year beginning on or after 1 January in the calendar year next following the year in which the Agreement enters into force.

b) in respect of other taxes, for taxes chargeable for any tax year beginning on or after 1 January in the calendar year next following the year in which the notice is given.

Such property shall, for the assessment of such duty, be considered as being in the State of domicile for tax purposes, subject to the rights of third States and to the possible application of provisions of international conventions on double taxation.

b) the Federal Republic of Germany is prevented from levying taxes on amounts which are to be included in the items of income of a resident of the Federal Republic of Germany under the Fourth Part of the German Law on External Tax Relations (Aussensteuergesetz).

All pecuniary executions of inspection measures and other rulings and resolutions issued on the basis of this act in connection with the payment of fines and supplementary payments stipulated and levied pursuant to this act shall be carried out by the relevant tax administration in the area where the person subject to inspection has permanent residence.

Movable property belonging to persons referred to in the preceding paragraph and situated in the territory of the country where they are staying shall be exempt from death duties in that country; such property shall, for the assessment of such duty, be considered as being in the country of domicile for tax purposes, subject to the rights of third countries and to the possible application of provisions of international conventions on double taxation.

shall in no circumstances be used other than for taxation purposes or in connection with judicial proceedings or administrative proceedings involving sanctions undertaken with a view to, or in relation to, the making or reviewing of the tax assessment.

Council Directive 77/799/EEC of 19 December 1977 concerning mutual assistance by the competent authorities of the Member States in the field of direct taxation, certain excise duties and taxation of insurance premiums(3) established the ground rules for administrative cooperation and the exchange of information between Member States in order to detect and prevent tax evasion and tax fraud and to enable Member States to carry out a correct tax assessment.

Such information shall include information that is foreseeably relevant to the determination, assessment, enforcement, recovery or collection of such taxes, with respect to persons liable to such taxes, or to the investigation or prosecution of tax matters in relation to such persons.

(3) If in the case referred to in the previous section a company declared a loss in its tax returns in the past five years, it loses the right to cover the declared loss by lowering its tax base in the following years up to an amount equalling the income which, due to the formation of provisions, by virtue of the previous section, does not form part of the tax base for assessing income tax.

Whereas the sixth Council Directive 77/388/EEC of 17 May 1977 on the harmonisation of the laws of the Member States relating to turnover taxes - Common system of value added tax: uniform basis of assessment(2), as last amended by Directive 1999/59/EC(3), specifies the notions of taxable person, of non-taxable person and of exempt activity;

differences in timing, e. g. payments may relate to tax assessments of several years;

The system does not impute missing taxes not evidenced by tax assessments.

in case of evasion of the payment of taxes on products (e. g. the payment of taxes is compulsory but there is no tax assessment), the estimate of taxes on products should therefore be lowered;

Taxes and subsidies on products are the amounts due for payment only when evidenced by tax assessments, declarations, etc, or the amounts actually paid (see paragraph 4. 27).

shall in no circumstances be used other than for taxation purposes or in connection with judicial proceedings or administrative proceedings involving sanctions undertaken with a view to, or in relation to, the making or reviewing the tax assessment.

Taxes evidenced by tax assessments but which are never paid (for instance, because of bankruptcy) are treated as if they had been paid;

For this reason, the amounts to be recorded in the system are determined by the amounts due for payment only when evidenced by tax assessments, declarations or other instruments which create liabilities in the form of clear obligations to pay on the part of taxpayers.

`Taxes evidenced by tax assessments but which are never paid (for instance, because of bankruptcy) are treated as if they had been paid; there are two eventualities:

`Taxes and subsidies on products are the amounts due for payment only when evidenced by tax assessments, declarations, etc. or the amounts actually paid (see point 4.27).`

Article 3 of Decision 85/257/EEC, Euratom shall continue to apply to the calculation and adjustment of revenue accruing from the application of rates to the uncapped uniform assessment basis for value added tax in 1987 and earlier years.

information forwarded to the one Member State by the competent authority of the other Member State has enabled information to be obtained which may be relevant in assessing liability to tax in the latter Member State.

uniform basis of assessment (1), progressively introduces a Community system of taxation applicable inter alia to works of art. Measures confined to the tax field are not sufficient to guarantee the harmonious functioning of the art market.

(e) information forwarded to the one Member State by the competent authority of the other Member State has enabled information to be obtained which may be relevant in assessing liability to tax in the latter Member State.

To benefit from the abovementioned tax deductions/ exemptions, a company must make the deduction/ exemption claim when submitting its tax return to the Tax Authorities at the end of the tax year.

shall in no circumstances be used other than for taxation purposes or in connection with judicial proceedings or administrative proceedings involving sanctions undertaken with a view to, or in relation to, the making or reviewing of the tax assessment.

Taxes (and subsidies) on products are usually estimated by product by applying the official tax (subsidy) rates to the various flows.Afterwards an analysis should be made of the differences with the tax assessments or the amounts actually paid.

It was also argued that this methodology cannot be applied to the alleged subsidisation amounts on tax credits since the tax credits, which the companies have claimed, are only utilised in the annual tax return which is made by 31 March of the following year.

However, the computations of the income tax in the tax return made by the company and the attached specifications showed that the company increased its depreciation of fixed assets significantly by changing assets from a category (machines) with a lower depreciation rate in the previous year's tax calculation to a category (moulds) with a significantly higher depreciation rate in the IP's tax calculation.

The GOT argued that the methodology whereby interest is added to the face value of the subsidy cannot be applied to the alleged subsidisation amounts on tax credits since the tax credits, which the companies have claimed, are only utilised in the annual tax return which is made by 31 March of the following year.

may be made known only in connection with judicial proceedings or administrative proceedings involving sanctions undertaken with a view to, or relating to, the making or reviewing the tax assessment and only to persons who are directly involved in such proceedings; such information may, however, be disclosed during public hearings or in judgements if the competent authority of the Member State supplying the information raises no objection,

may in addition be made known only in connection with judicial proceedings or administrative proceedings involving sanctions undertaken with a view to, or relating to, the making or reviewing the tax assessment and only to persons who are directly involved in such proceedings; such information may, however, be disclosed during public hearings or in judgements if the competent authority of the Member State supplying the information raises no objection,

Whereas the Member States should exchange, even without any request, any information which appears relevant for the correct assessment of taxes on income and on capital, in particular where there appears to be an artificial transfer of profits between enterprises in different Member States or where such transactions are carried out between enterprises in two Member States through a third country in order to obtain tax advantages, or where tax has been or may be evaded or avoided for any reason whatever;

(4) The abolition of taxation on interest and royalty payments in the Member State where they arise, whether collected by deduction at source or by assessment, is the most appropriate means of eliminating the aforementioned formalities and problems and of ensuring the equality of tax treatment as between national and cross-border transactions; it is particularly necessary to abolish such taxes in respect of such payments made between associated companies of different Member States as well as between permanent establishments of such companies.

Current and deferred tax assets and liabilities are usually measured using the tax rates (and tax laws) that have been enacted.

shall in no circumstances be used other than for taxation purposes or in connection with judicial proceedings or administrative proceedings involving sanctions undertaken with a view to, or in relation to, the making or reviewing the tax assessment. 2.

Accounting for the current and deferred tax effects of a transaction or other event is consistent with the accounting for the transaction or event itself.

uniform basis of assessment (3), the Council is to adopt a Community taxation system to be applied to used goods, works of art, antiques and collectors' items;

Indication of the tax arrangements with regard to any taxes and charges to be borne by the holders and levied in the countries where the certificates are issued.

The benefit relating to a tax loss that can be carried back to recover current tax of a previous period should be recognised as an asset.

Current tax is the amount of income taxes payable (recoverable) in respect of the taxable profit (tax loss) for a period.

When a tax loss is used to recover current tax of a previous period, an enterprise recognises the benefit as an asset in the period in which the tax loss occurs because it is probable that the benefit will flow to the enterprise and the benefit can be reliably measured.

the amount of the benefit arising from a previously unrecognised tax loss, tax credit or temporary difference of a prior period that is used to reduce current tax expense;

Council Directive 77/799/EEC of 19 December 1977 concerning mutual assistance by the competent authorities of the Member States in the field of direct taxation, certain excise duties and taxation of insurance premiums(3) established the ground rules for administrative cooperation and the exchange of information between Member States in order to detect and prevent tax evasion and tax fraud and to enable Member States to carry out a correct tax assessment.

whereas these resources are to include those accruing from value added tax and obtained by applying a common rate of tax on a basis of assessment determined in a uniform manner according to Community rules;

An enterprise will normally have a legally enforceable right to set off a current tax asset against a current tax liability when they relate to income taxes levied by the same taxation authority and the taxation authority permits the enterprise to make or receive a single net payment.

2.Where information for determining the taxable amount is expressed in a currency other than that of the Member State where assessment takes place, the exchange rate shall be determined in accordance with Article 12 of Regulation (EEC) No 803/68.

information forwarded to the one Member State by the competent authority of the other Member State has enabled information to be obtained which may be relevant in assessing liability to tax in the latter Member State. 2.

such property shall, for the assessment of such duty, be considered as being in the country of domicile for tax purposes, subject to the rights of non-member countries and to the possible application of provisions of international conventions on double taxation.