Tax & Legal

In her Opinion, the Advocate General suggested the European Court of Justice decide that Luxembourg has fulfilled its obligation to transpose the Anti-Tax-Avoidance-Directive (ATAD) into national law by including so called securitization companies in the list of 'financial undertakings' for which the interest limitation rule set forth in Article 4 ATAD is not applicable.

On 10 November 2023, the Bundestag passed the draft bill submitted by the German government on the EU directive on global minimum taxation. The vote was based on a recommendation by the Finance Committee.

Section 50d (9) Income Tax Act (ITA) excludes a tax exemption in Germany under a double tax treaty where, inter alia, the income is not taxed in the other treaty state.

The European Commission has drafted a proposed amendment to the Parent/Subsidiary Directive in the interests of closing perceived loopholes.