Current Changes in German Corporate Tax Law Tax Germany

Size: px
Start display at page:

Download "Current Changes in German Corporate Tax Law Tax Germany"

Transcription

1 Current Changes in German Corporate Tax Law Tax Germany Newsletter December 23, 2010 For further information please contact: Duesseldorf: Dr. Stephan Schnorberger bakermckenzie.com Juliane Sassmann bakermckenzie.com Steve Petrika Frankfurt: Christian Brodersen Muenchen: Udo Henkel Berlin Friedrichstrasse Berlin Tel.: +49 (0) Fax: +49 (0) Duesseldorf Neuer Zollhof Duesseldorf Tel.: +49 (0) Fax: +49 (0) Frankfurt / Main Bethmannstrasse Frankfurt/Main Tel.: +49 (0) Fax: +49 (0) Munich Theatinerstrasse Muenchen Tel.: +49 (0) Fax: +49 (0) Annual Tax Act 2010 On November 26, 2010 the Upper House of the German Parliament (Bundesrat), as expected, passed the Annual Tax Act 2010 (Jahressteuergesetz 2010, JStG 2010). The Annual Tax Act 2010 contains, amongst others, many amendments in the fields of corporate tax law and procedural law. We outline the most relevant in the following. 1. Theory of Final Withdrawal Codified Exit taxation on assets transferred from a German permanent establishment (PE) to a PE abroad has been a controversial issue in Germany for many years. Since December 7, 2006 the law equates the preclusion or the restriction of the German right to taxation on an asset with a sale or withdrawal of the asset. According to the official reasoning to the law, a particular example of a preclusion or restriction of the German right to taxation is given if the profit of the foreign PE is either exempted from German taxation or if (due to a double tax treaty) any foreign tax is credited against the German tax (the so-called finale Entnahmetheorie, theory of final withdrawal). It was controversial from the beginning whether the wording of the new law really covered cross-border asset transfers. Under the exemption method, Germany is still able to tax the hidden reserves built up in-country when the relevant asset is sold out of the foreign PE, so that the domestic right to taxation is neither precluded nor restricted. The Federal Tax Court (Bundesfinanzhof, BFH) lent support to this view in 2008 when it came to the same conclusion in an earlier case. Now, the Annual Tax Act 2010 explicitly states that when an asset is allocated to a foreign PE, there is a preclusion or restriction of the German right to taxation regarding the profits from the sale of this asset. Since the legislator views this amendment as a clarification, it shall apply to all cases that have not yet been closed. Given the legal doubts, it is advisable to consider legal remedies against relevant tax assessments. 2. Amendment of Separate Loss Carry Forward Assessments Any loss carry forwards remaining at the end of an assessment period are to be determined separately (Sec. 10d Para. 4 Sent. 1 Income Tax Law). According to the previous law, such a separate loss assessment notice is to be released, annulled or changed should the figures necessary for the determination of the loss carry forwards change, as long as the tax assessment note for the loss year is not

2 yet final (Sec. 10d Para. 4 Sent. 4 and 5 Income Tax Act). Departing from its previous opinion, the BFH ruled in 2008 that the first determination of a loss carry forward does not trigger Sec. 10d Para. 4 Sent. 4 and 5 Income Tax Act, because the figures necessary for the determination of the loss carry forward have not changed. Sec. 10d Para 4 Sent. 1 Income Tax Act is applicable instead. The retrospectively valid loss carry forward still has to be determined separately. The amendment to Sec. 10d Para. 4 Sent. 4 and 5 Income Tax Act in the Annual Tax Act 2010 means that now the determination of a remaining loss carry forward is, without exception, dependent on whether the tax assessment notice for the year the losses were realized is definitive or not, i.e. whether the corresponding tax assessment can still be amended. A corresponding amendment for trade tax loss carry forwards has also been included. These amendments came into effect as from December 13, However, the practical consequences of these changes are limited for enterprises, since the tax assessments are regularly issued with a review clause that allows both the tax administration and the taxpayer to change the tax assessment notes at a later date. 3. Loss carry forwards: Modification of the Hidden-Reserves-Rule in the Context of a Detrimental Share Purchase Until now, the cancellation of loss carry forwards due to a detrimental change in share ownership can be avoided to a certain extent. It can be avoided insofar as the loss carry forward does not exceed the taxable German hidden reserves taxable in Germany. According to the Annual Tax Act 2010, foreign hidden reserves shall also be taken into account if they are taxable in Germany (i.e. no double tax treaty or a double tax treaty with tax deduction clauses). In addition to this beneficial amendment for the taxpayer, the legislator has also established another modification regarding the determination of the hidden reserves in case the company has negative equity. Here, the hidden reserves shall be determined by deducting the (negative) book equity from the fair market value of the company s net assets (enterprise value). On the other hand, in case the company has positive equity, the fair market value of the shares is decisive. Through this amendment, the legislator tries to prevent the emergence of artificial hidden reserves, in particular where the buyer only pays a mark-up on the equity s book value in order to obtain future tax benefits by avoiding the cancellation of loss carry forwards. Both amendments shall be applied retroactively as of fiscal year Should the retroactive application lead to any unfavorable consequences, we would advise to consider legal remedy. 4. Tightening of the Controlled Foreign Company (CFC) Rules The German controlled foreign company rules (CFC rules, Hinzurechnungsbesteuerung) provide for passive income of a foreign, predominantly German held 2

3 company, to be directly attributed to the German shareholders if the passive income in the source state is taxed at a rate lower than 25%. Through inconsistencies in the handling and determination of the income, the CFC rules can lead to a higher tax rate for the passive income than if it had been directly obtained in Germany. Certain states tax the income of capital companies with a formal tax rate of 25% or more, but then provide significant tax relief to the shareholders. Some tax planning models seek to exploit this, since the formal criteria for the CFC rules are not met even though the passive income is taxed at an effective tax rate in the foreign state of less than 25%. The so-called double Malta model is a particularly well-known example of this. In order to undermine these tax planning models, the Annual Tax Act 2010 introduces a new rule so that direct or indirect tax relief for CFC shareholders is taken into account regarding the 25% threshold (the so-called consolidated perspective). The new rule is effective for passive income to be attributed in fiscal years starting after December 31, As a consequence of this amendment, the profits of potential intermediate companies could qualify as being low taxed and trigger the CFC rules for the first time. If this is the case, we would advise checking whether a restructuring of the group would be beneficial. Despite the amendment, serious doubts still exist as to whether the German CFC rules are in line with European law. 5. Controversial Binding Consultation Agreements regarding the Interpretation of Double Tax Treaties According to recent BFH decisions, inter-governmental agreements concluded between contracting states of double tax treaties to ensure consistent interpretations of the treaty, are not binding for German courts. The BFH qualifies these so-called consultation agreements as administrative agreements which are not based on constitutional, democratic legislation. Without parliamentary transformation into domestic law, inter-governmental agreements are not binding for German courts. The Annual Tax Act 2010 authorizes the German tax administration to transform such consultation agreements subject to approval by the Upper House to legislative regulations. This new law is unfortunate as it once more blurs the boundaries between the executive and the legislative power. The amendment was criticized with substantial constitutional doubts. In relevant cases, legal remedies should be considered. 6. Electronic Bookkeeping Abroad With the Annual Tax Act 2010, the criteria for transferring electronic bookkeeping abroad are both loosened and harmonized for EU and non-eu countries. Previously, one of the preconditions for electronic bookkeeping in a different EU state was that the relevant foreign state has to allow the German tax authorities 3

4 access to the bookkeeping data abroad. This rule was impractical. The Annual Tax Act 2010 replaces it by the precondition that German taxation is not negatively affected. It is also clarified that the taxpayer has the option of only transferring part of the bookkeeping. If German taxation is negatively affected by the transfer of the electronic bookkeeping into a foreign country (or if another precondition is not fulfilled), the tax authority has to withdraw its approval and demand the immediate transfer of the bookkeeping back to Germany. Violations can lead to a fine of up to EUR 250, Interest Income for Tax Reimbursements not Tax-free In its decision dated June 15, 2010 the BFH changed its opinion regarding the taxation of interest paid by the tax office on tax reimbursements. According to the new decision, the interest is not subject to tax as long as it is interest on nondeductible taxes. The BFH argues that by making the taxes payments nondeductible, the legislator also moved secondary payments such as interest to the non-taxable area. From this, the BFH concluded that the tax refund does not lead to income. This also applies to the interest applied to the refund as these are payments ancillary to the main refund. Through the Annual Tax Act 2010, the German legislator has reacted to this decision by introducing a rule that the interest income for tax reimbursement is part of the capital income and, thus, taxable. However, interest payments by the taxpayer are non-deductible from the tax base. This discriminatory treatment is said to be justified by the fact that, for a private person, interest payments on any debt are non-deductible while interest income is taxable. According to the official reasoning of the Annual Tax Act 2010, this new rule is only a clarification, so that it applies to all tax assessments which have no legal validity. Given the recent BFH decision, this is questionable. Doubts have also been raised regarding the constitutionality of the new rule. We thus advise to consider keeping open relevant tax assessment notices. 8. Maintenance of companies corporate income tax credits resulting from corporate tax regime applicable until 2000 In November 2009, the Federal Constitutional Court decided that the transition rules from the previous full credit system to the current classical corporate tax system violate the general equality principle guaranteed by the constitution. Under certain circumstances, these rules triggered the final loss of corporate income tax credit (paid). The Federal Constitutional Court obligated Parliament to establish new rules that are in line with the constitution for all open cases effective as from January 1, 2011 at the latest. Through the Annual Tax Act, the German legislator fulfilled this obligation by establishing new rules avoiding a loss of potential corporate income tax credits. Unfortunately, these new rules come too late for most companies, since their tax assessments for the relevant assessment period 2000 have already been closed. 4

5 9. Miscellaneous regarding Corporate Tax Law (1) The withholding tax on capital income (e.g. dividends, interest income) with its lump tax rate of 25% (plus 5.5% solidarity surcharge on the tax) also applies to foreign capital companies, as long as the parent subsidiary directive and double tax treaties do not provide for partial or full relief from withholding tax. To ensure an equal treatment with the German corporate tax rate of 15%, the Federal Central Tax Office (Bundeszentralamt für Steuern) refunds two fifths of this 25% upon application. In the past, this relief was restricted to some parts of capital income (in particular dividends). The new rule eliminates this restriction and applies for all capital flows enacted after December 31, (2) The Annual Tax Act 2010 clarifies that German branches of foreign insurance companies that are residents in the EU or in EEA countries have to apply the German methods for valuing claim provisions in their balance sheets. This was not completely clear since these domestic branches are not subject to the German Financial Supervising Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin). (3) As a consequence of the financial and economic crisis, certain insurance companies have been given more flexibility in determining their provisions for contribution reimbursement payments (Rückstellung für Beitragsrückerstattung, RfB) for the fiscal years 2010 to Corporate Tax: No Legal Clarification of the Requirements for Group Taxation regarding the Assumption of Losses A critical requirement for the establishment of group taxation (Organschaft) for limited liability corporations (Gesellschaft mit beschränkter Haftung, GmbH) is an agreement for the assumption of losses according to Sec. 302 of the German Stock Corporation Act (Aktiengesetz, AktG). Both the BFH and the tax authority interpreted the wording very strictly and demanded explicit references to each part of Sec. 302 AktG in its currently effective version. On the other hand, the Federal Supreme Court (Bundesgerichtshof, BGH) holds the opinion that, for civil/company law purposes, the presence of a profit transfer agreement causes an automatic obligation to assume any losses, as in Sec. 302 AktG. In other words, an explicit reference to the obligation to assume losses would be dispensable. Based on this case law of the BGH, the Bundesrat suggested a corresponding amendment of the debated rule in German tax law in order to harmonize it with current civil/company law by ruling that the assumption of losses need no longer be explicitly agreed, but simply has to exist in practice (e.g. via a profit transfer agreement). In the past, erroneous or forgotten explicit references to loss assumption in a profit transfer agreement for an Organschaft with a GmbH as the group head, have often led tax authorities to not recognize the Organschaft. Such a harmonization of corporate and tax law would have simplified matters for taxpayers. 5

6 Unfortunately, this proposal had not been included in the Annual Tax Act In accordance with a recent BFH decision, the Federal Ministry of Finance loosened the criteria in a publication dated October 19, 2010 by determining that a general reference citing Sec. 302 AktG is sufficient to fulfill the loss assumption obligation as a precondition for the Organschaft. The legislator views this clarification as being sufficient and did not take up the Bundesrat s proposal. Nevertheless, this new BFH interpretation makes it easier to establish an Organschaft. 11. Issues Not Addressed in the Annual Tax Act The implementation of a more simple, more flat and more fair tax regime, as was agreed by the new German government in September A reaction to the launching of two formal procedures against Germany by the European Commission. One deals with the restriction of withholding tax reimbursements for certain foreign companies. Another relates to the German restructuring privilege which allows loss carry forwards to be maintained despite a detrimental share purchase. - The Bundesrat had recommended intensifying the requirements for a penalty-free self accusation in the case of tax fraud. A gradual, piecemeal admission that increases with the risk of discovery should no longer be penalty-free. It was also recommended that the rules regarding the timing of such a declaration be tightened. The Bundestag has however not included these amendments in the Annual Tax Act Stephan Schnorberger Steve Petrika Juliane Sassmann This client newsletter is prepared for information purposes only. The information contained therein should not be relied on as legal advice and should, therefore, not be regarded as a substitute for detailed legal advice in the individual case. The advice of a qualified lawyer should always be sought in such cases. In the publishing of this Newsletter, we do not accept any liability in individual cases. Baker & McKenzie - Partnerschaft von Rechtsanwälten, Wirtschaftsprüfern, Steuerberatern und Solicitors is a professional partnership under German law with its registered offices in Frankfurt/Main, registered with the Local Court of Frankfurt/Main at PR No It is associated with Baker & McKenzie International, a Verein organized under the laws of Switzerland. Members of Baker & McKenzie International are Baker & McKenzie law firms around the world. In common with terminology used in professional service organizations, reference to a "partner" means a professional who is a partner, or equivalent, in such a law firm. Similarly, reference to an "office" means an office of any such law firm. 6

DOING BUSINESS IN GERMANY Overview on Taxation

DOING BUSINESS IN GERMANY Overview on Taxation DOING BUSINESS IN GERMANY Overview on Taxation March 2015 1. Introduction 1.1. Generally, taxes are administered and enforced by the competent local tax office. These local tax offices administer in particular

More information

Real estate acquisition structures in Europe: the main tax issues

Real estate acquisition structures in Europe: the main tax issues Real estate acquisition structures in Europe: the main tax issues The increasing budget requirements of European countries and their implications for taxpayers CMS Annual Tax Conference - Thursday 9 February

More information

15. 2. 2. 2. Is Section 10d of the Corporate Income Tax Act consistent with Article 9 of the OECD Model Tax Convention?

15. 2. 2. 2. Is Section 10d of the Corporate Income Tax Act consistent with Article 9 of the OECD Model Tax Convention? CHAPTER 15. SUMMARY AND CONCLUSIONS 15. 1. Introduction The main question addressed in this PhD thesis is whether the restrictions placed by Dutch law on deducting interest for corporate income tax purposes

More information

Summary of important tax law changes in Germany during the last months

Summary of important tax law changes in Germany during the last months Luther News, July 2008 German Tax News Summary of important tax law changes in Germany during the last months Various changes in German tax law have become effective in 2008 or will or are expected to

More information

Taxation of aircraft financing in Germany

Taxation of aircraft financing in Germany Financial institutions Energy Infrastructure, mining and commodities Transport Technology and innovation Life sciences and healthcare Taxation of aircraft financing in Germany Briefing September 2013 1

More information

International Tax Alert

International Tax Alert Global Insights A Review of Key Regulatory Issues Impacting International Tax Practices European Union: German dividend withholding tax violates the principle of free movement of capital (ECJ, October

More information

German Tax Facts. The Expatriate Financial Guide to Germany

German Tax Facts. The Expatriate Financial Guide to Germany The Expatriate Financial Guide to Germany German Tax Facts Introduction Tax Year Assessment Basis Income Tax Taxation in Germany occurs at a national and municipal level. The Ministry of Finance controls

More information

ENCHANCING PORTUGUESE CORPORATE TAX REGIME

ENCHANCING PORTUGUESE CORPORATE TAX REGIME December 2013 ENCHANCING PORTUGUESE CORPORATE TAX REGIME The Parliament has approved the Portuguese Corporate Income Tax Reform. This Reform, which follow largely the recommendations of the Reform Commission,

More information

ishares IV Public Limited Company

ishares IV Public Limited Company ishares IV Public Limited Company (An umbrella investment company with variable capital and having segregated liability between its Funds incorporated with limited liability in Ireland under registration

More information

Germany. Tax returns N/A. Annual returns are to be submitted as required by tax law, based on the (adjusted) commercial accounts.

Germany. Tax returns N/A. Annual returns are to be submitted as required by tax law, based on the (adjusted) commercial accounts. Germany International Comparison of Insurance * May 2009 Germany General Insurance Definition Definition of property and casualty insurance company A company carrying on any kind of direct insurance business

More information

A Global Guide To M&A Germany

A Global Guide To M&A Germany A Global Guide To M&A Germany by Nicole Fröhlich, Luther Rechtsanwaltsgesellschaft mbh (Taxand Germany) Contact: Nicole Froehlich nicole.froehlich@ luther-lawfirm.com, T. +49 69 27229 24830 This article

More information

Why Spain? Why Austria?

Why Spain? Why Austria? Briefing Overseas investments by Brazilian corporations Summary In this briefing we look at how the Austrian and Spanish domestic tax regimes for holding companies may be relevant when structuring international

More information

Implementation of the EU tax directives in Poland

Implementation of the EU tax directives in Poland Bartosz Bacia Implementation of the EU tax directives in Poland Since Poland joined the EU on May 1 2004, Polish tax law need to be adapted to the EU Council directives for the member states. The new legal

More information

Tax News. Contents. German Annual Tax Act 2009. 1 Introduction. Introduction 1

Tax News. Contents. German Annual Tax Act 2009. 1 Introduction. Introduction 1 Tax News. German Annual Tax Act 2009 Contents 1 Introduction On 28 November 2008 the German Parliament (Bundestag) adopted the German Annual Tax Act 2009 ( ATA 2009 ) in the second and third readings,

More information

www.ag.ch/steuern 1 on 13

www.ag.ch/steuern 1 on 13 Volume / Register Vol. II Reg. 11 Issue date July 30, 2015 DEPARTMENT OF FINANCES AND RESOURCES Cantonal Tax Office Status as at July 30, 2015 Valid as of Contents 1. Holding Companies... 3 1.1 Legal Bases...

More information

How To Limit Tax Competition In Swissitzerland

How To Limit Tax Competition In Swissitzerland Robert Waldburger University of St. Gallen Tax competition in Europe National Report Switzerland I. General aspects of the domestic tax situation 1. The notion of 'tax competition' in domestic legal and

More information

Italian corporate income tax for foreign investors

Italian corporate income tax for foreign investors Italian corporate income tax for foreign investors 05 October 15 Corporate income tax Italian corporate income tax (imposta sul reddito delle società, or IRES) is due by resident companies on their worldwide

More information

German REIT Act. A brief Overview with a Regulatory Framework.

German REIT Act. A brief Overview with a Regulatory Framework. German REIT Act. A brief Overview with a Regulatory Framework. The German REIT Act. German Real Estate Investment Trusts ( G-REITs ) Contents Where are we now? The current status Where are we now? 1 The

More information

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS

TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection

More information

www.fyb.de FINANCIAL YEARBOOK GERMANY PRIVATE EQUITY AND CORPORATE FINANCE ALTERNATIVE TYPES OF FINANCING THE REFERENCE BOOK ENTREPRENEURS INVESTORS

www.fyb.de FINANCIAL YEARBOOK GERMANY PRIVATE EQUITY AND CORPORATE FINANCE ALTERNATIVE TYPES OF FINANCING THE REFERENCE BOOK ENTREPRENEURS INVESTORS www.fyb.de english edition FYB FINANCIAL YEARBOOK GERMANY 2011 PRIVATE EQUITY AND CORPORATE FINANCE ALTERNATIVE TYPES OF FINANCING THE REFERENCE BOOK FOR AND ENTREPRENEURS INVESTORS FOR YOUR BUSINESS sponsored

More information

Survey on the Societas Europaea September 2003 Annex 6 - Germany GERMANY. International Bureau of Fiscal Documentation 1

Survey on the Societas Europaea September 2003 Annex 6 - Germany GERMANY. International Bureau of Fiscal Documentation 1 Annex 6 - Germany GERMANY International Bureau of Fiscal Documentation 1 Abbreviations: - EStG -> Einkommensteuergesetz Income Tax Law - GewStG -> Gewerbesteuergesetz Municipal Business Tax Law - KStG

More information

EU constraints on recent and expected tax changes in Belgium

EU constraints on recent and expected tax changes in Belgium EU constraints on recent and expected tax changes in Belgium D. Garabedian Madrid, 31 May 2014 Brussels London - www.liedekerke.com Overview Notional interest deduction (NID) Fairness tax Hybrid loans

More information

The Austrian Swiss Tax Agreement

The Austrian Swiss Tax Agreement Practice Group Tax, Austria Newsletter April 2012 For further information, please contact: The Austrian Swiss Tax Agreement In an unexpectedly speedy process, on April 13, 2012 Austria and Switzerland

More information

Budget 2016 CHANGES IN DUTCH TAXATION FOR 2016. www.fi sconti.com

Budget 2016 CHANGES IN DUTCH TAXATION FOR 2016. www.fi sconti.com Budget 2016 CHANGES IN DUTCH TAXATION FOR 2016 www.fi sconti.com Table of contents Changes in Dutch payroll and income tax Tax credits and rates in 2016 ----------- 3 Emigration of substantial interest

More information

Belgium in international tax planning

Belgium in international tax planning Belgium in international tax planning Presented by Bernard Peeters and Mieke Van Zandweghe, tax division at Tiberghien Belgium has improved its tax climate considerably in recent years. This may be illustrated

More information

The marketing of participations in foreign private equity funds from an Austrian tax perspective

The marketing of participations in foreign private equity funds from an Austrian tax perspective Seite 1 von 6 www.altassets.net The case for countries - Austria The marketing of participations in foreign private equity funds from an Austrian tax perspective Gerald Gahleitner, Gerald Toifl, Leitner

More information

Guidelines to the application form Admission of companies to Exchange trading

Guidelines to the application form Admission of companies to Exchange trading Guidelines to the application form Admission of companies to Exchange trading Preliminary remarks According to section 19 (1) of the German Exchange Act (Börsengesetz, BörsG), section 12 of the Exchange

More information

Europe. NEW OPPORTUNITIES FOR DIVIDEND WITHHOLDING TAX REFUNDS EU / EEA Tax Exempt Entities Handbook

Europe. NEW OPPORTUNITIES FOR DIVIDEND WITHHOLDING TAX REFUNDS EU / EEA Tax Exempt Entities Handbook Europe NEW OPPORTUNITIES FOR DIVIDEND WITHHOLDING TAX REFUNDS EU / EEA Tax Exempt Entities Handbook 3rd Edition April 2012 I n t r o d u c t i o n We are pleased to present the third edition of this handbook,

More information

Company Formation in Austria. Tax l Accounting l Audit l Advisory

Company Formation in Austria. Tax l Accounting l Audit l Advisory Tax l Accounting l Audit l Advisory Company Formation in Austria When considering an investment abroad thought must be given to taxation of income received as dividends and interest as well as any capital

More information

Holding companies in Ireland

Holding companies in Ireland Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation

More information

Brazilian interest payments on net equity (Juros sobre o capital próprio): an international perspective

Brazilian interest payments on net equity (Juros sobre o capital próprio): an international perspective Brazilian interest payments on net equity (Juros sobre o capital próprio): an international perspective 1. Interest on Equity and Dividends: the Brazilian perspective Brazilian companies have two main

More information

Netherlands Details Bank Tax Proposal

Netherlands Details Bank Tax Proposal Volume 65, Number 2 January 9, 2012 Details Bank Tax Proposal by Jean-Paul van den Berg and Johan Vrolijk Reprinted from Tax Notes Int l, January 9, 2012, p. 91 Reprinted from Tax Notes Int l, January

More information

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser

Value through Wealth Planning - Key trends in taxation of private investors. Prof. Pierre-Marie Glauser Value through Wealth Planning - Key trends in Prof. Pierre-Marie Glauser Introduction (1) Wealth Management & Taxes Funds are Not declared Declared No taxes due Tax planning not necessary Relevant tax

More information

www.ag.ch/steuern 1 of 10

www.ag.ch/steuern 1 of 10 Date of issue 1 st January 2011 DEPARTMENT OF FINANCE AND RESOURCES Cantonal Tax Administration Modifications Valid as of 2007 LEAFLET Contents 1. Holding Companies...2 1.1 Legal Bases...2 1.2 General...2

More information

Spain Tax Alert. Corporate tax reform enacted. Tax rate. Tax-deductible expenses. International Tax. 2 December 2014

Spain Tax Alert. Corporate tax reform enacted. Tax rate. Tax-deductible expenses. International Tax. 2 December 2014 International Tax Spain Tax Alert 2 December 2014 Corporate tax reform enacted Contacts Brian Leonard bleonard@deloitte.es Francisco Martin Barrios fmartinbarrios@deloitte.es Elena Blanque elblanque@deloitte.es

More information

Corporate Reorganizations Capabilities

Corporate Reorganizations Capabilities Corporate Reorganizations Capabilities Attorney Advertising Table of Contents Commercial Pragmatists: Our Global and Local Reorganizations Practice 4 Your German Reorganizations Team 5 Project Management

More information

FYB FINANCIAL. www.financial-yearbook.de english edition PRIVATE EQUITY YEARBOOK GERMANY ALTERNATIVE TYPES OF FINANCING THE REFERENCE BOOK

FYB FINANCIAL. www.financial-yearbook.de english edition PRIVATE EQUITY YEARBOOK GERMANY ALTERNATIVE TYPES OF FINANCING THE REFERENCE BOOK www.financial-yearbook.de english edition FYB FINANCIAL YEARBOOK GERMANY PRIVATE EQUITY ALTERNATIVE TYPES OF FINANCING THE REFERENCE BOOK FOR AND ENTREPRENEURS INVESTORS sponsored by Dr. Hans-Martin Schmid

More information

Belgian Dividend Tax Treatment of Nonresidents Illegal, ECJ Says

Belgian Dividend Tax Treatment of Nonresidents Illegal, ECJ Says Volume 68, Number 3 October 15, 2012 Belgian Dividend Tax Treatment of Nonresidents Illegal, ECJ Says by David Mussche Reprinted from Tax Notes Int l, October 15, 2012, p. 258 Reprinted from Tax Notes

More information

Annual International Bar Association Conference 2014. Tokyo, Japan. Recent Developments in International Taxation. Portugal. Guilherme Figueiredo

Annual International Bar Association Conference 2014. Tokyo, Japan. Recent Developments in International Taxation. Portugal. Guilherme Figueiredo Annual International Bar Association Conference 2014 Tokyo, Japan Recent Developments in International Taxation Portugal Guilherme Figueiredo Eurofin Capital S.A. gfigueiredo@eurofincapital.com 1. RECENT

More information

TAX DEVELOPMENTS IN POLAND UPDATE 2009

TAX DEVELOPMENTS IN POLAND UPDATE 2009 TAX DEVELOPMENTS IN POLAND UPDATE 2009 WARDYŃSKI & PARTNERS TAX PRACTICE APRIL 2010 1/8 INTRODUCTION The purpose of this report is to present key tax developments in Poland in 2009 which may be relevant

More information

The Introduction of Real Estate Investment Trusts [REITs] in Germany

The Introduction of Real Estate Investment Trusts [REITs] in Germany DEVELOPMENTS The Introduction of Real Estate Investment Trusts [REITs] in Germany By Constantin M. Lachner and Rafael von Heppe * A. Introduction The German Real Estate Investment Trust or, G-REIT is in

More information

European Tax Newsalert A Washington National Tax Services (WNTS) Publication Portugal December 20, 2011

European Tax Newsalert A Washington National Tax Services (WNTS) Publication Portugal December 20, 2011 European Tax Newsalert A Washington National Tax Services (WNTS) Publication Portugal December 20, 2011 Portugal 2012 Budget Act The Portuguese Parliament approved the 2012 Budget Act on November 30, 2011.

More information

In the following, we give a first overview of the proposed tax law amendments which are of particular importance:

In the following, we give a first overview of the proposed tax law amendments which are of particular importance: April 2010 Tax News. Annual Tax Act 2010 Draft Act dated 29 March 2010 Introduction On 29 March 2010, the Federal Ministry of Finance (Bundesfinanzministerium BMF) presented the draft (Referentenentwurf

More information

70. Switzerland. Other regulations

70. Switzerland. Other regulations 70. Switzerland Introduction Switzerland does not have specific transfer pricing regulations but respectively adheres to the Organisation for Economic Co-operation and Development (OECD) Guidelines. As

More information

TAX ISSUES RAISED BY LNG PROJECTS

TAX ISSUES RAISED BY LNG PROJECTS TAX ISSUES RAISED BY LNG PROJECTS Jon Lobb Baker Botts L.L.P. ABSTRACT This paper discusses tax issues that may be encountered by a company investing in an LNG project. 1. Income Taxes A seller's income

More information

Financial Report Annual Financial Report 2015

Financial Report Annual Financial Report 2015 Deutsche Postbank Funding Trust IV (a statutory trust formed under the Delaware Statutory Trust Act with its principal place of business in New York, NY, U.S.A.) Financial Report Annual Financial Report

More information

Tax Year 2013 - Income 2012

Tax Year 2013 - Income 2012 L UNION FAIT LA FORCE - EENDRACHT MAAKT MACHT Federal Public Service FINANCE NOTIONAL INTEREST DEDUCTION: an innovative Belgian tax incentive Tax Year 2013 - Income 2012 www.invest.belgium.be 2 Content

More information

Mexico Mergers and acquisitions involving Mexican assets

Mexico Mergers and acquisitions involving Mexican assets p84-88 IM&A - Chevez Rulz 21/03/2013 08:44 Page 84 Mexico Mergers and acquisitions involving Mexican assets by Ricardo Rendon and Layda Carcamo, Chevez, Ruiz, Zamarripa y Cia, S.C. Whenever a corporate

More information

A 5.5% solidarity surcharge is imposed on the income tax liability of all taxpayers.

A 5.5% solidarity surcharge is imposed on the income tax liability of all taxpayers. Worldwide personal tax guide 2013 2014 Germany Local information Tax Authority Website Tax Year Tax Return due date 31 May 2013 Is joint filing possible Are tax return extensions possible 2013 income tax

More information

1. What changes are foreseen in the Law on income tax from 1.1.2016?

1. What changes are foreseen in the Law on income tax from 1.1.2016? This newsletter covers the following topics: 1. What changes are foreseen in the Law on income tax from 1.1.2016?... 1 2. Proposed changes to the Tax Code, with effect from 01.01.2016... 2 3. Proposed

More information

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE EN EN EN EUROPEAN COMMISSION Brussels, COM(2010) COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE Removing cross-border tax obstacles

More information

Conflicts and Issues under The U.S. - India Tax Treaty

Conflicts and Issues under The U.S. - India Tax Treaty TAX TREATIES Conflicts and Issues under The U.S. - India Tax Treaty Shefali Goradia*, Carol P. Tello** When the income tax treaty between India and the United States ( Treaty ) was negotiated in the late

More information

The Special Non-resident Tax Regime for Expatriate Employees in Belgium

The Special Non-resident Tax Regime for Expatriate Employees in Belgium H UMAN C APITAL t The Special Non-resident Tax Regime for Expatriate Employees in Belgium Contents 1. Qualifying Conditions 2. The special tax regime a. Generalities b. Non-taxable allowances c. Calculation

More information

MALTA Jurisdictional Guide

MALTA Jurisdictional Guide MALTA Jurisdictional Guide GENERAL INFORMATION The Republic of Malta is situated in the centre of the Mediterranean, south of Sicily, east of Tunisia and north of Libya. Malta gained its independence from

More information

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income.

Income in the Netherlands is categorised into boxes. The above table relates to Box 1 income. Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl

More information

18 August 2015. 1. Amendments to the participation exemption regime

18 August 2015. 1. Amendments to the participation exemption regime 18 August 2015 Luxembourg draft legislation introducing EU anti hybrid and anti-abuse provisions in the participation exemption regime and a horizontal consolidation tax regime. On 5 August 2015, the Minister

More information

Intellectual Property Rights (IP-Box) in Luxembourg

Intellectual Property Rights (IP-Box) in Luxembourg Intellectual Property Rights (IP-Box) in Luxembourg I. Intellectual Property-Box (IP-Box) in Luxembourg II. Intellectual property rights (IP) in Luxembourg III. Company for Intellectual Property Rights

More information

Life Goes On: The Second Life of the German Trade Tax

Life Goes On: The Second Life of the German Trade Tax Volume 48, Number 3 October 15, 2007 Life Goes On: The Second Life of the German Trade Tax by Wolfgang Kessler and Rolf Eicke Reprinted from Tax Notes Int l, October 15, 2007, p. 279 F eatured Perspectives

More information

COMMISSION OF THE EUROPEAN COMMUNITIES REPORT FROM THE COMMISSION TO THE COUNCIL

COMMISSION OF THE EUROPEAN COMMUNITIES REPORT FROM THE COMMISSION TO THE COUNCIL EN EN EN COMMISSION OF THE EUROPEAN COMMUNITIES Brussels, 15.9.2008 COM(2008) 552 final REPORT FROM THE COMMISSION TO THE COUNCIL in accordance with Article 18 of Council Directive 2003/48/EC on taxation

More information

G E N C S V A L T E R S L A W F I R M B A L T I C T A X C A R D 2 0 1 5

G E N C S V A L T E R S L A W F I R M B A L T I C T A X C A R D 2 0 1 5 CORPORATE INCOME TAX IN BALTICS Corporate Income Tax Rates in Baltics Country Standard rate Decreased rate Transfer of loses to next periods Latvia 15% 11% microenterprises Unlimited Lithuania 15% Estonia

More information

Bank Levies in the UK, France and Germany

Bank Levies in the UK, France and Germany Bank Levies in the UK, France and Germany A Comparison of the New Levies on Banks SUMMARY The United Kingdom, France and Germany have all recently finalised, or are in the process of finalising, details

More information

GLOBAL GUIDE TO M&A TAX

GLOBAL GUIDE TO M&A TAX Quality tax advice, globally GLOBAL GUIDE TO M&A TAX 2013 EDITION www.taxand.com CYPRUS Cyprus From a Buyer s Perspective 1. What are the main differences among acquisitions made through a share deal versus

More information

TAX ASPECTS REGARDING THE MERGER AND DIVISION

TAX ASPECTS REGARDING THE MERGER AND DIVISION TAX ASPECTS REGARDING THE MERGER AND DIVISION Ph.D. Associate Professor BRAGĂ FILOFTEIA VIORICA Spiru Haret University, Faculty of Accounting and Finance Câmpulung, viobraga@yahoo.com Ph.D. Lecturer NĂFTĂNĂILĂ

More information

The Impact of Introducing an Interest Barrier

The Impact of Introducing an Interest Barrier 1215 Discussion Papers Deutsches Institut für Wirtschaftsforschung 2012 The Impact of Introducing an Interest Barrier Evidence from the German Corporation Tax Reform 2008 Hermann Buslei and Martin Simmler

More information

Setting up your Business in SINGAPORE Issues to consider

Setting up your Business in SINGAPORE Issues to consider SINGAPORE is commerce, industry, heritage, culture and entertainment all rolled into a little island of slightly over 700 square kilometres with a population of 5.4 million. Here at the crossroads of Asia,

More information

Fire Protection Tax Act

Fire Protection Tax Act Übersetzung durch den Sprachendienst des Bundesministeriums der Finanzen. Translation provided by the Language Service of the Federal Ministry of Finance. Stand: Die Übersetzung berücksichtigt die Änderung(en)

More information

New German Thin Cap Rules Too Thin the Cap

New German Thin Cap Rules Too Thin the Cap Volume 47, Number 3 July 16, 2007 New German Thin Cap Rules Too Thin the Cap by Wolfgang Kessler and Rolf Eicke Reprinted from Tax Notes Int l, July 16, 2007, p. 263 New German Thin Cap Rules Too Thin

More information

Structuring of Investment Managed Accounts for Alternative Investment Funds

Structuring of Investment Managed Accounts for Alternative Investment Funds Uwe Bärenz Attorney at Law and Partner at P+P Pöllath + Partners, Berlin 2 Uwe Bärenz P+P Pöllath + Partners Structuring of Investment Managed Accounts Over the last few years, German institutional investors

More information

FOLLOW UP WORK ON BEPS ACTION 6: PREVENTING TREATY ABUSE

FOLLOW UP WORK ON BEPS ACTION 6: PREVENTING TREATY ABUSE Public Discussion Draft FOLLOW UP WORK ON BEPS ACTION 6: PREVENTING TREATY ABUSE 21 November 2014 9 January 2015 TABLE OF CONTENTS Discussion draft (cover note)... 4 A. s related to the LOB provision...

More information

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013

WLP LAW. II. The Dutch corporate tax system. INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 INVESTING IN INDIA OR THE UNITED STATES OF AMERICA THROUGH THE NETHERLANDS Tax Alert April 2013 i Tel +31 I. (0)88 Introduction 2001300 Cell +31 (0)6 M The Netherlands is an attractive and advantageous

More information

Belgium: Tax treatment of immigrating taxpayers

Belgium: Tax treatment of immigrating taxpayers Belgium: Tax treatment of immigrating taxpayers IFA Congres Madrid 30 May 2014 Marc Vandendijk Tax Lawyer VANDENDIJK & PARTNERS Rue Edith Cavellstraat 66 1180 Brussels Tel.: + 32 (0)2.343.33.45 E-MAIL:

More information

TAX DRIVEN M&A STRUCTURES IN GERMANY A special report by Florian Schultz and Axel Mielke, Linklaters Oppenhoff & Rädler, Frankfurt

TAX DRIVEN M&A STRUCTURES IN GERMANY A special report by Florian Schultz and Axel Mielke, Linklaters Oppenhoff & Rädler, Frankfurt TAX DRIVEN M&A STRUCTURES IN GERMANY A special report by Florian Schultz and Axel Mielke, Linklaters Oppenhoff & Rädler, Frankfurt Tax climate Once again, the German government is planning to tighten German

More information

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies

CLIENT ATTORNEY PRIVILEGED WORK PRODUCT. Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies Jurisdictional comparison The Netherlands Luxembourg Cyprus Holding companies CORPORATE/LEGAL Incorporation time and costs Possible in 3 days app. EUR 2,500 Less than a week app. EUR 4,000 Up to 2 weeks

More information

25*$1,6$7,21)25(&2120,&&223(5$7,21$1''(9(/230(17

25*$1,6$7,21)25(&2120,&&223(5$7,21$1''(9(/230(17 25*$1,6$7,21)25(&2120,&&223(5$7,21$1''(9(/230(17 7D[3ROLF\5HIRUPVLQ,WDO\ &(175()257$;32/,&

More information

TAX LETTER for May 2004 INCOME ATTRIBUTION RULES SPLIT INCOME OF MINOR CHILDREN FEDERAL BUDGET HIGHLIGHTS AROUND THE COURTS

TAX LETTER for May 2004 INCOME ATTRIBUTION RULES SPLIT INCOME OF MINOR CHILDREN FEDERAL BUDGET HIGHLIGHTS AROUND THE COURTS BLAIN M. ARCHER, B.Sc., CA* PAUL M. FOURNIER, B.Sc., CA* RUSS J. WILSON, B.Sc., CA* KATRIN BRAUN, B.B.A., CA* KELLY A. RIEHL, B. Comm., CA* TAX LETTER for May 2004 INCOME ATTRIBUTION RULES SPLIT INCOME

More information

Delivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad

Delivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad Delivering U.S. International Tax Advice to U.S. Clients Doing Business Abroad OGLE INTERNATIONAL TAX ADVISORS www.ogleintltax.com OUR INTERNATIONAL TAX PRACTICE INCLUDES BOTH CPAS AND ATTORNEYS WITH BIG

More information

Indonesia: National Manpower Security Agency (BPJS Ketenagakerjaan) and National Healthcare Security Agency (BPJS Kesehatan)

Indonesia: National Manpower Security Agency (BPJS Ketenagakerjaan) and National Healthcare Security Agency (BPJS Kesehatan) Global Employment Solutions Global InSight 30 January 2015 In this issue: Indonesia: National Manpower Security Agency (BPJS Ketenagakerjaan) and National Healthcare Security Agency (BPJS Kesehatan)...

More information

Receita Federal do Brasil (RFB) www.receita.fazenda.gov.br 1 January to 31 December Last working day of April following end of tax year

Receita Federal do Brasil (RFB) www.receita.fazenda.gov.br 1 January to 31 December Last working day of April following end of tax year Worldwide personal tax guide 2013 2014 Brazil Local Information Tax Authority Receita Federal do Brasil (RFB) Website www.receita.fazenda.gov.br Tax Year 1 January to 31 December Tax Return due date: Last

More information

TAXATION AND FOREIGN EXCHANGE

TAXATION AND FOREIGN EXCHANGE TAXATION OF EQUITY HOLDERS The following is a summary of certain PRC and Hong Kong tax consequences of the ownership of H Shares by an investor that purchases such H Shares in the Global Offering and holds

More information

14. Corporate Tax and Depreciation

14. Corporate Tax and Depreciation 14. Corporate Tax and Depreciation Corporate income tax is levied on income from the worldwide operations of Czech tax residents and on Czech-source income of Czech tax non-residents. Czech tax residents

More information

German Inheritance Tax

German Inheritance Tax German Tax Law German nheritance Tax This article provides a brief introduction to the German inheritance tax. Jerome Synold, Attorney-At-Law Jan-Hendrik Frank, German Attorney-At-Law German nheritance

More information

Cross Border Tax Issues

Cross Border Tax Issues Cross Border Tax Issues By Reinhold G. Krahn December 2000 This is a general overview of the subject matter and should not be relied upon as legal advice or opinion. For specific legal advice on the information

More information

The UK as a holding company location

The UK as a holding company location The UK as a holding company location Tax May 2013 kpmg.com A key ambition is to create the most competitive tax system in the G20. As well as lowering tax rates, the Government wants to make the UK the

More information

TAX PLANNING INTERNATIONAL

TAX PLANNING INTERNATIONAL TAX PLANNING INTERNATIONAL EUROPEAN TAX SERVICE International Information for International Business >>>>>>>>>>>>>>>>>>>>>>>>>>>>> VOLUME 17, NUMBER 3 >>> MARCH 2015 www.bna.com EU Financial Transaction

More information

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005

450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Eric van Aalst Mark Riedy Citco Corporate Services Inc. Andrews Kurth LLP 450 Lexington Ave 1350 I Street, NW Suite 3320 Suite 1100 New York, NY 10017 Washington, DC 20005 Structuring International Operations

More information

Domination and. Profit and Loss Transfer Agreement

Domination and. Profit and Loss Transfer Agreement Domination and Profit and Loss Transfer Agreement between Celesio AG, Neckartalstraße 155, 70376 Stuttgart registered in the commercial register (Handelsregister) at the Local Court (Amtsgericht) Stuttgart

More information

Intellectual Property Box (IP-box) Liechtenstein

Intellectual Property Box (IP-box) Liechtenstein Intellectual Property Box (IP-box) Liechtenstein I. Intellectual Property Box (IP box) in Liechtenstein II. Intellectual property rights (IP) in Liechtenstein III. IP company in Liechtenstein IV. Advantages

More information

Share redemption 2016

Share redemption 2016 Share redemption 2016 Information for shareholders in HiQ International AB (publ) regarding the Board s proposal for a share split and mandatory redemption procedure Background BACKGROUND HiQ International

More information

US Citizens Living in Canada

US Citizens Living in Canada US Citizens Living in Canada Income Tax Considerations 1) I am a US citizen living in Canada. What are my income tax filing and reporting requirements? US Income Tax Returns A US citizen residing in Canada

More information

Eye-on-China Webinar Series. Befriend the Chinese Tiger Keep Risk At Bay and Optimize Your China Opportunities

Eye-on-China Webinar Series. Befriend the Chinese Tiger Keep Risk At Bay and Optimize Your China Opportunities Eye-on-China Webinar Series Befriend the Chinese Tiger Keep Risk At Bay and Optimize Your China Opportunities Eye-on-China Webinar Series Taxation of Foreign Investors in China: Dramatic Climate Change

More information

Highlights of the New Dutch Tax Treaty Policy

Highlights of the New Dutch Tax Treaty Policy Volume 62, Number 9 May 30, 2011 Highlights of the New Dutch Tax Treaty Policy by Jean-Paul van den Berg and Johan Vrolijk Reprinted from Tax Notes Int l, May 30, 2011, p. 727 Highlights of the New Dutch

More information

MALTA: A JURISDICTION OF CHOICE

MALTA: A JURISDICTION OF CHOICE MALTA: A JURISDICTION OF CHOICE LONDON - September 2012 Doing business from Malta can make a huge difference for your business UHY BUSINESS ADVISORY SERVICES LIMITED Updated September, 2012 An attractive

More information

Tax Reform in Brazil and the U.S.

Tax Reform in Brazil and the U.S. Tax Reform in Brazil and the U.S. Devon M. Bodoh Principal in Charge Latin America Markets, Tax KPMG LLP Carlos Eduardo Toro Director KPMG Brazil Agenda Overview of Global Tax Reform Overview Organization

More information

Monaco Corporate Taxation

Monaco Corporate Taxation Introduction Monaco is a sovereign principality. France is a guarantor of the sovereignty and territorial integrity of Monaco, while Monaco is to conform to French interests. Although the Prince is the

More information

The Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan

The Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan The Bank of Nova Scotia Shareholder Dividend and Share Purchase Plan Offering Circular Effective November 6, 2013 The description contained in this Offering Circular of the Canadian and U.S. income tax

More information

Tax-efficient cross-border finance structures: opportunities and constraints

Tax-efficient cross-border finance structures: opportunities and constraints Tax-efficient cross-border finance structures: opportunities and constraints The increasing budget requirements of European countries and their implications for taxpayers CMS Annual Tax nference - Thursday

More information

SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014

SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014 TAX BRIEFING SPANISH TAX REFORM: MAIN ISSUES FOR M&A AND FINANCING TRANSACTIONS DECEMBER 2014 THIS BRIEFING FOCUSES ON THOSE MEASURES INCLUDED IN THE CIT ACT WHICH AFFECT M&A, FINANCING & REFINANCING TRANSACTIONS.

More information

How to establish a business in Germany

How to establish a business in Germany How to establish a business in Germany Andreas Seidel seidel@butzel.com BUTZEL LONG A PROFESSIONAL CORPORATION 150 WEST JEFFERSON, SUITE 100 DETROIT, MI 48226 TEL: 313 225 7000 I FAX: 313 225 7080 www.butzel.com

More information

Slovenia. Chapter. Avbreht, Zajc & Partners Ltd. 1 General: Treaties. 2 Transaction Taxes. Ursula Smuk

Slovenia. Chapter. Avbreht, Zajc & Partners Ltd. 1 General: Treaties. 2 Transaction Taxes. Ursula Smuk Chapter Avbreht, Zajc & Partners Ltd. Ursula Smuk 1 General: Treaties 1.1 How many income tax treaties are currently in force in? 44 income tax treaties are currently in force in. 1.2 Do they generally

More information

International: Parent-Subsidiary Directive: the European Commission suggests changes to prevent tax evasion

International: Parent-Subsidiary Directive: the European Commission suggests changes to prevent tax evasion Tax Topics amongst others: Businesses: Changes to German travel expenses laws (Reisekostenrecht) 2014 International: Parent-Subsidiary Directive: the European Commission suggests changes to prevent tax

More information