Germany - New Guidelines from Ministry of Finance on Tax Treatment of Decrease in Value of Loans to Affiliated Companies
- S. Rasch; J. Maier
- International Transfer Pricing Journal, 2011 (Volume 18), No 4
- 20 July 2011
The Annual Tax Act 2008 brought new rules on the tax treatment of losses resulting from loans to affiliated companies. In response to two notable court rulings, the Ministry of Finance has now issued guidelines on the same subject, which primarily apply to fiscal years before the law itself was revised. This article discusses certain aspects of the new rules in greater detail, by means of several examples.