EU Council to adopt ATAD II Directive on hybrid mismatches

On 29 May 2017 the Council of the EU formally and unanimously adopted the Council Directive amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countries (ATAD II).

Government draft for the implementation of the Anti-Tax Avoi ...

On 24 March 2021, a government draft bill aiming to implement the Anti-Tax Avoidance Directive (ATAD) passed the cabinet (in the following referred to as “Draft”) after lengthy political efforts.

Tax & Legal Newsflash – ATAD Implementation Act: Government ...

On 24 March 2021, a government draft bill aiming to implement the Anti-Tax Avoidance Directive (ATAD) passed the cabinet (in the following referred to as “Draft”) after lengthy political efforts.

Bundesrat approves several tax laws (including ATAD Implemen ...

At its session on 25 June, the Bundesrat approved several tax laws.

Tax & Legal Newsflash - draft ATAD Implementation bill

On 10 December 2019, the Federal Ministry of Finance (MoF) provided various federations and associations with a draft bill on the Implementation of the Anti-Tax Avoidance Directive (ATAD Implementation Act) for comment. The decision of the Cabinet has already been scheduled for 18 December 2019.

Tax & Legal Newsflash - 1 October 2020

Information on the Finance Bill 2020 (Bundesrat Committees submit recommendations to Bundesrat).

Tax & Legal News - December 2019

Our December 2019 Newsletter includes news about forthcoming legislation and news from the Supreme Tax Court.

UPDATE : Bundestag passes the Act to Modernise the Relief of ...

On 5 May 2021, the Bundestag passed the Act to Modernise the Relief of Withholding Taxes and the Certification of Capital Gains Tax. The law as passed is based on the resolution recommended and passed by the Bundestag Finance Committee on 21 April 2021.

Update: EU Commission proposal to reduce the imbalance in th ...

On 11 May 2022, the European Commission published a draft Directive which is intended to mitigate the tax induced debt-equity bias in corporate investment decisions. Technically, this is to be achieved through, on the one hand, an allowance that provides for the deductibility of notional interest on equity and, on the other, by introducing further restrictions on the deductibility of interest on debt.

Tax & Legal News – Issue 3, June 2017

In this issue: PwC Reports, Official pronouncements, Supreme Tax Court Cases and From Europe

MoF publishes draft of a revised circular on the interest li ...

On 10 October 2024 the Federal Ministry of Finance (MoF) published a first draft of a revised BMF circular on the interest limitation provisons in Section 4a Income Tax Act (ITA) and Section 8a Corporate Tax Act (CTA). Due to various amendments which took place in the course of the Act to Promote the Secondary Credit Market (Kreditzweitmarktförderungsgesetz) the tax administration sees the need for revisions.

Extension of the deadline for filing tax returns

On 25 June 2021, the Bundesrat approved the extension of the filing deadline for the 2020 tax return by three months.

Bundesrat approves a partial implementation of the Growth Op ...

On 15 December 2023, the Bundesrat approved the partial implementation of the contents of the Growth Opportunities Act in the Act to Promote the Secondary Credit Market. This includes changes to the interest limitation rule and adjustments resulting from the introduction of the Act for the Modernisation of Partnerships.

Tax & Legal Newsflash - Italy issues draft circular on hybri ...

The Italian Tax Authorities (ITA) launched, on October 18, a public consultation on the draft interpretative Circular Letter (the ‘Draft Circular’), which, at 111 pages, covers the application of the hybrid mismatch arrangements rules (the ‘Hybrid Rules’) as governed by Legislative Decree 142/2018 (the ‘ATAD Decree’) that implements the ATAD Directives through domestic italian legislation.

新ドイツCFC税制（タックスヘイブン税制）の施行

New decree by Federal Ministry of Finance extends motive tes ...

On 17 March 2021, the German Federal Ministry of Finance (BMF) published a decree on the application of Section 8 (2) of the Foreign Tax Act (AStG) which stipulates the “motive test” taxpayers have to meet to escape controlled foreign company (CFC) taxation.

MoF: Draft for revision of attribution taxation for foreign ...

The Federal Ministry of Finance (MoF) has sent the draft of a revised version of the attribution taxation for foreign family foundations pursuant to Section 15 of the Foreign Tax Act to certain associations. They as well as interested professionals are given the opportunity to comment until 15 January 2026.

Ministry of Finance: Draft Finance Bill 2022

On 28 July 2022, the Federal Ministry of Finance (MoF)) sent its draft of a Finance Bill 2022 to the industry associations with a request for comments by August 11.

EU draft directive to end the misuse of shell entities for t ...

On 22 December 2021 the European Commission presented a draft directive to prevent the abuse of shell companies for tax purposes whereby amending the Anti-Tax Avoidance Directive (ATAD 3). The proposal should ensure that entities in the EU that have no or minimal economic activity are unable to benefit from any tax advantages and do not place any financial burden on taxpayers.

Federal Cabinet approves government draft of the Growth Oppo ...

At its closed-door meeting in Meseberg on 30.8.2023, the Federal Cabinet adopted the government draft for a law to enhance growth opportunities, investment, and innovation as well as tax simplification and tax fairness (Growth Opportunities Act).