Examples of using Thin cap in English and their translations into Hungarian
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In Thin Cap the ECJ acknowledged that measures to prevent thin capitalisation are not per se impermissible.
MSs should thereforenot be precluded from applying CFC and thin cap rules in relation to third countries.
The Commission shares the view of Advocate General(AG) Geelhoed who, in Thin Cap, opined that the setting out of reasonable presumptive criteria contributes to a balanced application of national anti-abuse measures as it is in the interest of both legal certainty for the taxpayers, and workability for tax authorities16.
Those provisions confer rights on individuals(Test Claimants in the FII Group Litigation, paragraph 211,and Test Claimants in the Thin Cap Group Litigation, paragraph 117).
There are many different approaches to the design of thin cap rules which reflect the different views and legal traditions of MSs.
That also includes losses constituted by the unavailability of sums of money as a result of a tax being levied prematurely(Test Claimants in the FII Group Litigation, paragraph 205,and Test Claimants in the Thin Cap Group Litigation, paragraph 112).
The EESC's reservations would appear tobe echoed in the European Court of Justice's Thin Cap ruling, which states that"measures to prevent thin capitalisation are not per se impermissible.
It follows from Cadbury and Thin Cap that, for the purposes of determining whether a transaction represents a purely artificial arrangement, national anti-abuse rules may comprise'safe harbour' criteria to target situations in which the probability of abuse is highest.
In such a case, that its application be appropriate to ensuring the attainment of the objective in question and not go beyond what is necessary to attain it(see Case C-446/03 Marks& Spencer[2005] ECR I-10837,paragraph 35; Cadbury Schweppes and Cadbury Schweppes Overseas, paragraph 47; and Test Claimants in the Thin Cap Group Litigation, paragraph 64). 28.
The Commission considers that the principles laid down by the ECJ in relation to thin cap rules also apply to transfer pricing rules, which are essential to the continued existence of individual national tax systems.
TEST CLAIMANTS IN THE CFC AND DIVIDEND GROUP LITIGATION had not applied for a tax advantage which national law denied them, with a view to challenging the refusal of the tax authorities by means of the legal remedies provided for that purpose,invoking the primacy and direct effect of Community law(Test Claimants in the Thin Cap Group Litigation, paragraph 125).
The above-cited judgments in Cadbury Schweppes and Cadbury Schweppes Overseas, Test Claimants in Class IV of the ACT Group Litigation,Test Claimants in the FII Group Litigation and Test Claimants in the Thin Cap Group Litigation were communicated to the referring court by letter of 3 April 2007, so that it could inform the Court whether, in the light of those judgments, it wished to maintain its reference for a preliminary ruling.
It is therefore for the national court to determine whether the expenditure referred to in paragraph 114 of the present order represents, in the case of the companies concerned, financial losses suffered by reason of a breach of Community law for which the Member State in question is responsible(see, to that effect, Test Claimantsin the FII Group Litigation, paragraph 208, and Test Claimants in the Thin Cap Group Litigation, paragraph 114).
In the present case, in order to determine whether a breach of Article 43 EC or Article 56 EC committed by the Member State concerned is sufficiently serious, the national court must take into account the fact that, in a field such as direct taxation, the consequences arising from the freedoms of movement guaranteed by the Treaty have been only gradually made clear(Test Claimants in theFII Group Litigation, paragraph 215, and Test Claimants in the Thin Cap Group Litigation, paragraph 121).
On any view, the Court has already stated that a breach of Community law will clearly be sufficiently serious if it has persisted despite a judgment finding the infringement in question to be established, or a preliminary ruling or settled caselaw of the Court on the matter, from which it is clear that the conduct in question constituted an infringement(Test Claimants in the FII Group Litigation, paragraph 214,and Test Claimants in the Thin Cap Group Litigation, paragraph 120).
Those factors include, in particular, the clarity and precision of the rule infringed, whether the infringement and the damage caused were intentional or involuntary, whether any error of law was excusable or inexcusable, and the fact that the position taken by a Community institution may have contributed to the adoption or maintenance of national measures or practices contrary to Community law( Test Claimants in the FIIGroup Litigation, paragraph 213, and Test Claimants in the Thin Cap Group Litigation, paragraph 119).
Wash and dry your hands.• Open the tube(the first time you use the tube you will need to break the seal using the spike in the top of the cap).• Squeeze the cream onto your finger.•Apply a thin layer of< Invented Name> and completely cover the affected skin.• Apply only on areas affected with eczema• Rub in gently and fully.• Replace the cap on the tube.
When choosing autumn or winter hats for children,it is important to consider what You are going to poddevat under the hat(cap or thin beanie).
Um, thin, uh, Jean jacket, cap, blue eyes.
Often down jackets are equipped with hoods with fur trim or without it,in that case under the hood you can wear a thin knitted or fabric cap.
Be sure to take a disposable diaper- pampers, cap, socks, two diapers- thin and flannel.
The neck of the vessel is best covered with a thin layer of gauze, but in no case a cap cap.
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The inner surface of the cap is represented by a thin spongy layer.
The underside of these caps is covered with a thin layer of densely packed pores.
Transfer printing is perfect for printing very thin lines and small details even on places that seem impossible(T-shirt sleeves, pockets, collars, baseball caps, ties).
She had a thin tank top whose straps are not covered bra straps and on top of a zipper and, to cap it all, a pair of sheer pink sweatpants.
The ice cap is 40% thinner than 40 years ago.