(1) A special investment fund's income-related expenses that are directly economically connected with income are direct costs. Direct costs also include deductions for wear and tear or depletion up to the amounts permitted under section 7 of the Income Tax Act. The special investment fund's remaining income-related expenses are general costs.
(2) Direct costs directly economically connected with income under section 20(1) no. 1 or (2), first sentence, no. 1 of the Income Tax Act are to be allocated exclusively to income under section 20(2), first sentence, no. 1 of the Income Tax Act. Where there is no income under section 20(2), first sentence, no. 1 of the Income Tax Act, or the income is lower than the income-related expenses, the special investment fund must form loss carryforwards.
(3) Losses from financial derivatives are to be deducted as direct costs from income under section 20(2), first sentence, no. 1 of the Income Tax Act where the special investment fund has, as part of a structured arrangement, brought about losses from financial derivatives and, in the same or a similar amount, income under section 20(2), first sentence, no. 1 of the Income Tax Act.
(4) The direct costs remaining after the allocation under subsections (2) and (3) are to be deducted from the respective income.
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Section 39
Income-related expenses, deduction of direct costs
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