Voorbeelden van het gebruik van Deutsche shell in het Engels en hun vertalingen in het Nederlands
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However, Deutsche Shell has suffered an exchange rate loss.
It confines itself to the contention that Deutsche Shell has suffered no real loss.
DEUTSCHE SHELL does not seek to argue that there is no restriction.
Is there an advantage which offsets the disadvantage suffered by Deutsche Shell in this case?
Therefore the disadvantage suffered by Deutsche Shell is attributable to the decisions of the German authorities.
On 17 July 1992, the monies realised on the sale of the shares to Edison were transferred to Deutsche Shell.
In Germany Deutsche Shell has unlimited liability to tax on its worldwide income under Paragraph 1(1) of the KStG.
The Finanzamt argues that that the description of the facts given by Deutsche Shell is largely fictive, as is the currency loss itself.
Thus Deutsche Shell takes as its model for comparison a German parent company with an establishment in Germany, which operates in more than one currency.
The amount in Italian lira obtained as a result of the above transactions was paid to Deutsche Shell on 17 July 1992 as reimbursement of the‘startup capital.
Deutsche Shell then sold the shares acquired through that transfer to an independent Italian company Edison Gas SpA.:‘Edison.
The unusual factual circumstances of this case prompted a question from the Court, in which Deutsche Shell and the Finanzamt were asked to provide details of the repatriation of profits.
On 28 February 1992 Deutsche Shell transferred the assets of the branch to a wholly-owned subsidiary(Sierra Gas SrL.:‘Sierra')
According to the facts as stated by the referring court, the claimant before that court, Deutsche Shell GmbH(‘Deutsche Shell'), is a company which has its seat and principal place of business in Germany.
Deutsche Shell, a capital company with its registered office
In establishing whether the German law discriminates against Deutsche Shell in such a way as to infringe its right to freedom of establishment,
Deutsche Shell provided its branch with startup capital,
it would appear that Deutsche Shell has suffered a real disadvantage which would indeed restrict the exercise of the freedom of establishment.
As both Deutsche Shell and the Commission have highlighted in their observations,
Germany and the Netherlands submit that the coherence of the German fiscal system might be compromised if Deutsche Shell were permitted to take a currency loss into account when calculating its global profits for taxation in Germany.
DEUTSCHE SHELL invisible during the Italian tax computation in ITL,
As a consequence of exercising its right to freedom of establishment, Deutsche Shell has suffered a loss which cannot be taken into account in the valuation of its global profits for the purposes of tax assessment.
Deutsche Shell and the Commission confine themselves to the first question,
In other words, one single economic process is split artificially for the benefit of Deutsche Shell, since the income of the permanent establishment is exempt under the Convention
As Deutsche Shell had achieved an overall profit for 1992 through its Italian branch,
They also state that Deutsche Shell and the permanent establishment formed a single economic entity
Both the Commission and Deutsche Shell emphasise that, were the exchange rate losses instead an exchange rate profit,
In the calculation of Deutsche Shell's taxable income for the 1992 financial year the Finanzamt refused to take that loss into consideration in the corporation tax assessment notice it sent to Deutsche Shell on 19 September 1997.
Germany argues that Deutsche Shell is seeking to offset the taxation of the sales profit in Italy(which amounted to DEM 95 551 905 of tax)
DEUTSCHE SHELL by applying its own tax law and thereby calculate the