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Germany - Recent Changes to the German Fiscal Unity Regime Affecting Inbound Investors

Country:
Germany
Author:
M. Weiss
Issue:
European Taxation, 2019 (Volume 59), No 9
Published:
13 August 2019
This article describes the German fiscal unity regime for corporate and trade tax purposes (Organschaft). For inbound investors in particular, the German fiscal unity regime used to offer a straightforward opportunity to debt finance acquisitions of German operating companies. Recent legislative changes, however, have made base erosion in Germany via debt push-downs substantially more difficult in this context. With a German partnership as a top holding company, withholding tax issues may still be avoided.
 
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