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In recent years, there has been a steep increase in criminal proceedings for tax matters in some European countries, such as France,...
In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
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Germany has a general anti-abuse rule (GAAR) as well as other purpose tests under various specific anti-abuse rules (SAARs) in different...
Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
In practice, the beneficial ownership test is most often applied in connection with dividend withholding taxes but may also be relevant...
A far-reaching reform of the German real estate transfer tax (RETT) rules has been proposed which, if implemented, is intended to apply...
The German register cases have been the subject of discussions in the public and also in this blog for almost three years, from the start...
The German tax authorities have adopted the controversial "signing closing theory" for share deals involving at least 90% of the shares...
The 2021 reform of the German Real Estate Transfer Tax Act (Grunderwerbsteuergesetz or GrEStG) included, among other things, three...
On 16 June 2022, the German Federal Ministry of Finance (MoF) submitted to the finance committee of the German parliament its evaluation...
The German Federal Fiscal Court (Bundesfinanzhof, BFH) published its long-awaited ruling on the legality of so-called "cum ex"-structures...
Two recent trends in international taxation – an increase in taxpayers' obligations to document and share information with tax...
The German legislature has enacted a large number of new and amending provisions with remarkable speed, just before the current...
The German Ministry of Finance has published guidance on the transitional provision with respect to the revised German Real Estate...
As an aftermath to recent fiscal court decisions on cum/cum transactions, the German Federal Ministry of Finance ("BMF") has reconsidered...
The reform of the German Real Estate Transfer Tax (RETT) Act took a decisive step towards implementation. Since the RETT reform focuses...