schöne Analyse von Edison!
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"The Luxembourg tax losses were accumulated by the Luxembourg parent company before the IPO. The Luxembourg tax authorities have no obligation to assess the usability of the tax losses until they are used and any plans to use the tax losses would require third-party tax advice given the anti-avoidance legislation in place. As the parent company has no operational business and limited income in Luxembourg, GFG is unlikely to be able to utilise these losses.
The tax losses in the operating entities can be carried forward against future taxable income subject to local taxes and regulations, although in Brazil that they can only be offset against 30% of taxable income per year. Management has advised that the tax loss carry forwards could be challenged by the countries in which GFG operates and therefore may have a lower apparent value." |