MOF releases draft bill with postponed measures from 2015 tax bill

Global Tax Update:April 2015/Germany

On 20 February 2015, Germany’s Ministry of Finance (MOF) issued a draft bill that contains several measures that originally were part of the 2015 budget but that were postponed, but it does not include other deferred measures, such as the introduction of an anti-hybrid and anti-double dip rule.(Global Tax Update:April 2015/Germany)

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This newsletter explains following topics;

(1) The draft bill includes the following:

1) A broadening of the intragroup restructuring exception to the change-in-ownership rules:
2) Real Estate Transfer Tax (RETT) rules for real estate held by partnerships:
3) Reorganizations with “boot”:

(2) The draft bill does not include the following:

1) Introduction of an anti-hybrid and anti-double-dip rule:
2) Introduction of a 10% minimum
3) Centralization of the competency for certain withholding tax reclaims based on EU law in the Federal Tax Office:


>> Click for Japanese [ドイツ財務省:2015年税制改正案を公表、オーナーシップ変更による繰越欠損金利用制限の緩和、ほか]

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