Experts at KPMG examine an FTT decision concerning the income tax exemption and non-UK pension funds.
During the tax years under appeal BAV-TMW-Globaler-Immobilien Spezialfonds (BTI) a German real estate investment fund received income from UK property investments. The ultimate beneficial owner of BTI was a German pension scheme Bayerische Ärtzeversorgung (BÄV). As a matter of German law BTI was tax transparent and so BÄV was entitled to the income from BTI’s UK property investments as it arose.
BÄV was established by the Bavarian Parliament in 1923 as a pension scheme for doctors dentists and vets. It is administered by Bayerische Versorgungskammer (BVK) an administrative body for Bavarian pension schemes which forms part of a ministerial department.
Under German law BÄV qualified for exemption from German corporate income tax by virtue of its status as...
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Experts at KPMG examine an FTT decision concerning the income tax exemption and non-UK pension funds.
During the tax years under appeal BAV-TMW-Globaler-Immobilien Spezialfonds (BTI) a German real estate investment fund received income from UK property investments. The ultimate beneficial owner of BTI was a German pension scheme Bayerische Ärtzeversorgung (BÄV). As a matter of German law BTI was tax transparent and so BÄV was entitled to the income from BTI’s UK property investments as it arose.
BÄV was established by the Bavarian Parliament in 1923 as a pension scheme for doctors dentists and vets. It is administered by Bayerische Versorgungskammer (BVK) an administrative body for Bavarian pension schemes which forms part of a ministerial department.
Under German law BÄV qualified for exemption from German corporate income tax by virtue of its status as...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
