There`s a new fact. The fact that the person concerned would receive an irrevocable and unconditional offer on the shares, as well as how the share price would be determined and the minimum price of the shares, is the result of documents that the inspector did not previously have. There is no official omission. The inspector only studied the qualification of the CV. There was no other obligation to investigate the inspector, since at the time of the imposition of taxation, there was no unlikely possibility that there would be a control unit of Vpb. 1.When a subject (parent company) holds legal and economic ownership of at least 95% of the freed capital in the appointment of another taxpayer (subsidiary), the tax is collected at the request of the two taxpayers. , in the sense that there was a taxable person, since the subsidiary`s activities and assets existed in the activities and assets of the parent company. The tax is levied on the parent company. In this case, the tax payers are considered tax units. More than one subsidiary can be part of a control unit. Is there a VPB control unit between the individual and [E BV] this year? The Tribunal considers that there is a first issue to consider whether there is a VPB control unit between the individual and [E BV]. 2. A shareholding in paragraph 1 also refers to an average portfolio of shares, provided that they are held without delay by one or more subjects in the tax unit.
5. The tax unit is set at a date to be determined by those subject to the application under paragraph 1, but not more than three months before the date on which the application was made. With respect to the request to reduce the interim assessment of Vpb 2010, the interested party did not provide a detailed explanation of the investments in the vessels. At the time of the final taxation, the inspector did not have access to the participation agreement, the tax-sharing agreement and the concept card. He had access only to the limited partnership contract and the annual accounts of his resume.