In a recently published decision, the German Federal Fiscal Court (BFH) ruled that the German thin capitalisation regulations (interest barrier rule) may violate the principles of fair taxation as laid down in the German Constitution. Affected taxpayers should take all measures to keep their assessments open and to stay the execution of their tax assessment notice.
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A recent UK First-tier Tribunal decision highlights the broad application of an anti-avoidance rule to deny tax relief, say Robert Waterson and Matthew Cummings of Eversheds Sutherland
The ruling underscores that tax authorities must provide ‘detailed, well-supported, and logically sound justifications’ when determining reference prices in tax assessments, one expert told ITR