Betekenis van:
gratuitous

Voorbeeldzinnen

1. Exceptional and gratuitous advantages
2. government grants are rarely gratuitous.
3. Under current law, all the exceptional and gratuitous advantages received will be added to the taxable income obtained by the cost plus method.
4. An alternative base including the exceptional and gratuitous advantages is calculated nevertheless, in order to limit exceptional transfers of income to the Belgian coordination centre.
5. The alternative tax base, based in particular on these exceptional and gratuitous advantages (see paragraph 15 of the initiating Decision), will be abandoned.
6. As to the alternative measures proposed by Belgium, only those are described which adapt the coordination centres scheme as regards the consideration given to exceptional and gratuitous advantages.
7. Under current ordinary tax law, this means that all the exceptional and gratuitous advantages will have to be added to the amount obtained by the cost plus method.
8. Belgium has announced that it could, in addition, adopt new provisions exempting, in certain cases, income deriving from exceptional and gratuitous advantages.
9. Under these conditions the Commission considers that no specific economic advantage is granted any longer to approved coordination centres as regards the tax treatment of the exceptional and gratuitous advantages received.
10. As regards the exceptional and gratuitous advantages accorded to centres, Belgium undertakes to amend the Law of 24 December 2002 so that such advantages receive the same tax treatment as the similar advantages received by other firms established in Belgium.
11. The exceptional or gratuitous advantages [12] conferred on the centre by the members of the group are not added to the tax base obtained by the cost plus method.
12. The procedure was initiated with regard to: 1. the specific exemption from withholding tax; 2. the specific exemption from capital duty, and 3. the non-taxation of the abnormal and gratuitous advantages accorded to the centres.
13. Belgium undertakes to adapt the coordination centres scheme, so that the exceptional and gratuitous advantages accorded to centres are subject to the same tax rules as the similar advantages received by other undertakings established in Belgium.
14. The concept of exceptional or gratuitous advantage, used in Article 26 of the Code des Impôts sur les Revenus 1992 (Income Tax Code), is explained in No 26/16, Commentaire du Code des Impôts sur les Revenus (Com.IR 1992).
15. Following the initiating Decision, Belgium explained how it interpreted the Commission's approval concerning the cost plus method and undertook to adapt the rules on withholding tax, capital duty and the exceptional and gratuitous advantages received.