May 16, 2020

Double standards for the taxation of intra-group financing

Dr. Ingmar Dörr, Dr. Andreas Eggert, Graham Poole, Dr. Mathias Schönhaus

Hogan Lovells

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The German Federal Ministry of Finance has published a draft law for the implementation of the EU Anti-Tax Avoidance Directive (ATAD Implementation Act) on 10 December 2019. This draft includes inter alia a new section 1a German Foreign Tax Act (Außensteuergesetz – AStG) on cross-border intra-group financing. This article explores how the implementation of this proposal would further increase the legal uncertainty in this area.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.