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Tax-free dividends from third countries - relief from the trade tax intercompany privilege

If an entrepreneur subject to trade tax receives dividends from foreign corporations, these dividends are taxable under the conditions of the so-called trade tax intercompany privilege (Section...

Withholding tax: BMF comments on damages, goodwill refunds and portfolio commissions passed on in connection with capital investments

In a letter dated 18 January 2019, the German Federal Ministry of Finance (BMF) addressed, among other things, the treatment of "special fees and benefits" in connection with...

Persistently low interest rates and continued high interest on tax arrears?

For a long time, the interest rate of 6% p.a. seemed to be set in stone in tax law. Painfully, for a very long time...

VAT group 2019 - partnerships as controlled companies

The instrument of group taxation in the form of a consolidated tax group can be found both in income tax law and in VAT law and is generally...

Real estate transfer tax for group reorganisations - Section 6a GrEStG not prohibited aid under EU law

The real estate transfer tax (GrEStG), with its tax rates that have now risen by up to 6.5%, is often an obstacle to restructuring or represents an obstacle for the...

Federal Council approves "Annual Tax Act 2018"

The so-called Annual Tax Act 2018 is "through" with the approval of the Bundesrat. All that remains to be done to finalise the legislative process is to sign...

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