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German federal tax court: withholding tax obligation for interest payments under PIK and subordinated loans?

  • Freshfields Bruckhaus Deringer LLP
  • -
  • Germany
  • -
  • December 15 2010

According to a judegement of the German Federal Tax Court, a loan agreement providing that interest payments are due and payable only if the debtor has sufficient liquidity may lead to the consequence that interest payments under the are subject to withholding tax

Substitute tax regime court decision puts some bridge financing structures at risk

  • Freshfields Bruckhaus Deringer LLP
  • -
  • Italy
  • -
  • November 24 2009

It is quite common in the Italian market to structure leveraged buy-out transactions andor real estate finance transactions with a bridge loan and later refinance the bridge facility with a secured long-term facility agreement