Translation of "Doppelter abzug" in English

In this respect it is noted that the investigation has established clearly that the investigated schemes that the exporting producers used during the IP (import duty exemption on machinery, double deduction from taxable income, and export tax compensation) are countervailable subsidies in line with the provisions of the basic anti-subsidy Regulation.

A double deduction means that the same payment is deductible from the taxable base in more than one jurisdiction.

To take into account this so-called dual inclusion 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.

At the point in time after the singling, ultrasonic sensor 13 determines the presence of an either single-layer or double-layer bank note, so that a signal is generated, according to which a single pick or double pick is present.

This resulted in the abolition of the double tax deduction.

Subsequent to the disclosure, VIZ STAL claimed that part of the financial costs incurred and deducted from the export price under Article 2(10)(g) of the basic Regulation was included in the related importer's SG&A and that the calculation of the constructed export price should therefore be revised to avoid a double deduction of these costs.

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.

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.

Consequently, the rules on hybrid mismatches and tax residency mismatches should apply to all taxpayers that are subject to corporate tax in a Member State including to permanent establishments, or to arrangements treated as permanent establishments, of entities resident in third countries.

Since hybrid mismatches could 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 appropriate.

The rules laid down in Article 9, paragraph 1, also apply to a hybrid permanent establishment mismatch leading to a double deduction.

A dual resident mismatch may result in a double deduction outcome if a payment made by a dual resident taxpayer is deducted under the laws of both jurisdictions where the taxpayer is resident.

In case of a double deduction or a deduction without inclusion, the same rules should apply as for neutralising a hybrid entity mismatch leading to a double deduction or to a deduction without inclusion respectively.

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.

In order to benefit from this scheme, the company must posses a Certificate of promotion which specifies that it is entitled to double deduction from taxable income of transportation, electricity, and water costs pursuant to Article 35(2) of the IPA.