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3.7.5. Starting Point for Acquisition/Loss of Fiscal Residence

The acquisition or loss of fiscal residence usually applies to the entire relevant year of income. However, depending on the type of income, the calculation of the exact amount of taxes payable may refer to the period in the year during which the company was resident, as for example, in the case of the taxation of capital gains (see below). Moreover, as seen above, the application of other rules, such as those governing company consolidation, have the effect of making relevant the time when a company becomes resident or ceased to be resident. In such cases, the date on which the non-resident company becomes a member of the consolidated group or when a resident company ceases to be such a member becomes important, since the relevant computations (e.g. the tax debt of the group) can only be made with reference to the period in the year during which the group – including the company concerned – was consolidated.