Germany's Federal Constitutional Court rules change-in-ownership rules partially unconstitutional
In a taxpayer-favorable decision issued on 29 March 2017 and published on 12 May 2017, Germany’s Federal Constitutional Court held that the change-in-ownership rules relating to loss carryforwards partially infringe the German constitution, and must be amended with retroactive effect.
SAT Issued New Rules to Improve Administration of Special Tax Investigation and Adjustment and Mutual Agreement Procedures
On 17 March 2017, the State Administration of Taxation (SAT) issued new regulations to improve administration of Special Tax Investigation and Adjustment and Mutual Agreement Procedures (i.e. Bulletin 6, or Bulletin).