Aug 5, 2008 18:55
15 yrs ago
2 viewers *
German term
Steuerverhaftungsquote
German to English
Bus/Financial
Law: Taxation & Customs
"Steuerverhaftungsquote derivativ einbringungsgeborener Anteile"
Good grief. Is there a simple way to say this in English?
Good grief. Is there a simple way to say this in English?
Proposed translations
(English)
| 4 | s.u. |
RobinB
|
| 3 | tax exposure ratio |
Adrian MM. (X)
|
Proposed translations
37 mins
Selected
s.u.
There's no even halfway equivalent to this in English tax rules AFAIK, so you're going to have to write round it a bit without losing the sense.
"steuerverhaftet" simply means "taxable", in the sense of remaining taxable for a period, rather than inherently taxable
"derivativ" here I would translate as "indirectly"
einbringungsgeborene Aktien = tainted shares (well documented in the professional literature, see also http://www.proz.com/kudoz/german_to_english/law:_taxation_cu...
and my own presentation on German Tax at the 2006 ATA conference)
giving something like:
"proportion of indirectly tainted shares that remains taxable", or possibly "taxable portion of indirectly tainted shares".
And that's the simple way :-)
"steuerverhaftet" simply means "taxable", in the sense of remaining taxable for a period, rather than inherently taxable
"derivativ" here I would translate as "indirectly"
einbringungsgeborene Aktien = tainted shares (well documented in the professional literature, see also http://www.proz.com/kudoz/german_to_english/law:_taxation_cu...
and my own presentation on German Tax at the 2006 ATA conference)
giving something like:
"proportion of indirectly tainted shares that remains taxable", or possibly "taxable portion of indirectly tainted shares".
And that's the simple way :-)
4 KudoZ points awarded for this answer.
Comment: "thanks a lot, Robin. This is as good as it gets in terms of providing even more than I had asked for....."
38 days
tax exposure ratio
I agree, on the second part, that 'tainted shares' is a term used in English-speaking countries other than the UK e.g. the US, India and Oz. One reason it is not in E&W is the unfortunate mix-up with 'tainted acquittals' in criminal law.
Exposure would literally fasten on the shares, rather than the term liability would, and also suggests a temporary, event-induced state of affairs.
We also need to analyse why this issuance of shares for a non-cash consideration is not a hold-over relief scenario e.g. the tax is held over or deferred to a subsequent sale.
Exposure would literally fasten on the shares, rather than the term liability would, and also suggests a temporary, event-induced state of affairs.
We also need to analyse why this issuance of shares for a non-cash consideration is not a hold-over relief scenario e.g. the tax is held over or deferred to a subsequent sale.
Example sentence:
Gehen infolge einer Kapitalerhöhung stille Reserven von einbringungsgeborenen Alt-Anteilen auf die neuen Anteile über, sind die neuen Anteile zu gleicher ...
to investors, which results in significant tax exposure for ... as capture ratio, tax efficiency, relative wealth and tax. burden, compare before-tax ...
Reference:
http://www.jurablogs.com/de/steuerverhaftungsquote-derivativ-einbringungsgeborener-anteile
http://www.alliancebernstein.com/CmsObjectABD/PDF/InvestorEducation/R25294_BitingBack_0704.pdf
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