Traduction de «Plus-values et moins-values des placements non réalisés » (Français → Anglais) :

‘realised gains on investments’, representing gains on the disposal of investments;

the retrospective effectiveness is demonstrated if the ratio between the actual gain/loss on the hedged item and the actual loss/gain on the hedging instrument is within the range of 80 %-125 %.

— Premium: the difference between the par value of a security and its price when this price is higher than par.

2. By way of derogation from paragraph 1, where the Member State of the transferring company applies a system of taxing worldwide profits, that Member State shall have the right to tax any profits or capital gains of the permanent establishment resulting from the merger, division, partial division or transfer of assets, on condition that it gives relief for the tax that, but for the provisions of this Directive, would have been charged on those profits or capital gains in the Member State in which that permanent establishment is situated, in the same way and in the same amount as it would have done if that tax had actually been charged a ...[+++]nd paid.

The system of deferral of the taxation of the capital gains relating to the assets transferred until their actual disposal, applied to such of those assets as are transferred to that permanent establishment, permits exemption from taxation of the corresponding capital gains, while at the same time ensuring their ultimate taxation by the Member State of the transferring company at the date of their disposal.

—appreciation or depreciation of investments,