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Federal Council Approves New Law Limiting Royalty Deductions

Germany - July 5 2017 On 2 June 2017, the German Federal Council approved a new law introducing a so-called royalty barrier (Lizenzschranke). Accordingly, as of 1 January…

Christoph Becker, Lars H. Haverkamp, Dr. Dr. Norbert Mückl, Dr. Stephan Schnorberger

Forfeiture of Unused Tax Losses Pursuant to German Corporate Income Tax Act Partly Unconstitutional

Germany - June 7 2017 In its decision published on 12 May 2017 (file no. 2 BvL 6/11), the Federal Constitutional Court (Bundesverfassungsgericht; BVerfG) ruled that the…

Dr. Cristan Gerhold, Dr. Dr. Norbert Mückl

Federal Tax Court Confirms Availability of 'Banking Privilege'

Germany - May 1 2017 In its recent decision dated December 6, 2016 (I R 79/15), the Federal Tax Court confirmed the availability of the banking privilege as stipulated in…

Stephan Behnes, Ludmilla Maurer, Dr. Dr. Norbert Mückl

Waiver of Debt No Taxable Event for Non-resident Real Estate Companies

Germany - April 27 2017 In its decision dated December 7, 2016 (file no. I R 76/14), the Federal Fiscal Court (Bundesfinanzhof; “BFH”) confirmed that the book gain from a…

Dr. Dr. Norbert Mückl

Germany: New tax exemption for debt restructuring gains in Germany

European Union, Germany - April 12 2017 With its judgment of November 28, 2016, the German Supreme Tax Court (Bundesfinanzhof; “BFH”) dismissed the application of the tax administration’s…

Dr. Dr. Norbert Mückl