Examples of using Double deduction in English and their translations into German
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Colloquial
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Official
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Ecclesiastic
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Medicine
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Financial
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Ecclesiastic
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Political
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Computer
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Programming
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Official/political
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Political
Hybrid entity mismatch leading to a double deduction.
Single parents receive a double deduction for dependent children.
This difference in qualification may lead to double exemptions or double deductions.
A double deduction means that the same payment is deductible from the taxable base in more than one jurisdiction.
The rules laid down in Article 9, paragraph 1,also apply to a hybrid permanent establishment mismatch leading to a double deduction.
Hence, you see, my double deduction that you had been out in vile weather, and that you had a particularly malignant boot- slitting specimen of the London slavey.
Those mismatches may lead to non-taxation without inclusion, a double deduction or a deduction without inclusion, and should therefore be eliminated.
Hence, you see, my double deduction that you had been out in vile weather, and that you had a particularly malignant boot- slitting specimen of the London slavey.
Another area concerns the use of hybrid entities, i.e. entities which are regarded as a corporate body(opaque) by one Member State and as non-corporate(transparent) by another MemberState; this difference in qualification by Member States may lead to double exemptions or double deductions.
This may lead to a double deduction of the same payment, expenses or losses or to a deduction of a payment without a corresponding inclusion of that payment.
If the same entity is treated as transparent in the jurisdiction of the holder of the equity interest in the entity, those payments, expenses or losses may be deductible from the taxablebase of the holder of the equity interest in that jurisdiction as well, leading to a double deduction within the meaning of Article 2, paragraph 9, subparagraph a.
A dual resident mismatch may lead to a double deduction if a payment made by a dual resident taxpayer is deducted under the laws of both jurisdictions where the taxpayer is resident.
Therefore, it is proposed to include rules that disallow the deduction of a payment if the income from such payment is set-off, directly or indirectly, against a deduction that arises under a hybrid mismatch arrangement giving rise to a double deduction(Article 9, paragraph 4) or a deduction without inclusion(Article 9, paragraph 5) between third countries.
Taxpayers may benefit from low tax rates or double deductions or ensure that their income remains untaxed by making it deductible in one jurisdiction whilst this is not included in the tax base across the border either.
Its consequences include double deductions(e.g. the same expense is deducted in both the state of source and the state of residence) and double non-taxation e.g. income is not taxed in either its state of source or in the recipient's state of residence.
Under the Directive,typical tax congruency between two States includes double deduction of expenses, deduction of an expense without it being included in the recipient's income, or double offset of deductions at source in different States.
In case of a double deduction or a deduction without inclusion, the same rules should apply as forneutralising a hybrid entity mismatch leading to a double deduction or to a deduction without inclusion respectively.
To take into account this so-called dualinclusion of income the proposal aims to neutralise a double deduction only to the extent that the same payment, expenses or losses deducted in two jurisdictions exceed the amount of income that can be attributed to the same hybrid entity and that is included in both jurisdictions.
A hybrid permanent establishment mismatch may lead to a double deduction within the meaning of Article 2, paragraph 9, subparagraph a, if a payment, expenses or losses are deductible from the taxable base both in the jurisdiction in which the taxpayer is a resident and in the jurisdiction of the hybrid permanent establishment where the payment, expenses or losses can be deducted.
As hybrid entity mismatches involving third countries may lead to a double deduction or to a deduction without inclusion, it is necessary to lay down rules whereby the Member State concerned either denies the deduction of a payment, expenses or losses or requires the taxpayer to include the payment in its taxable income, as the case may be.