Special features - February 2015

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Special features - February 2015

special-features-red3.jpg

Read this month's special features on Germany

German tax planning: Anti-hybrid financing measures

Germany has acted before the OECD’s final recommendations on hybrid mismatches by including anti-hybrid financing measures in the 2013 Annual Tax Act. Oliver Wehnert and David Martiny of EY explore whether the German legislation is producing the results the government wants and look at how the law should change, as well as assessing the likelihood of this happening.

Inheritance relief on business property transfer unconstitutional

Lothar Siemers and Martin Liebernickel of PwC explain the background to, and fallout from, a recent judgment stating that inheritance tax relief on the transfer of business property is unconstitutional.

New era for dependent agent PEs in Germany?

Susann van der Ham and Guido Schepers of PwC discuss the recently approved ordinance on the application of the arm’s-length principle to permanent establishments (PEs), addressing the impact of the introduced section 39 of the ordinance on the attribution of profits to dependent agent PEs in Germany to analyse whether the ordinance approval signals the start of an era of dependent agent PE discussions.

German self-disclosure rule amendments 2015

Hilmar Erb and Sebastian Lattmann of PwC explore new amendments to Germany’s self-disclosure rules, which have contributed to an increased compliance burden for taxpayers in 2015.

2014 roundup: German tax developments

Claus Jochimsen of PwC gives an overview of the tax law changes introduced under the label of the ZollkodexAnpG.

more across site & shared bottom lb ros

More from across our site

The Australian Taxation Office believes the Swedish furniture company has used TP to evade paying tax it owes
Supermarket chain Morrisons is facing a £17 million ($23 million) tax bill; in other news, Donald Trump has cut proposed tariffs
The controversial deal will allow US-parented groups to be carved out from key aspects of pillar two
Awards
ITR invites tax firms, in-house teams, and tax professionals to make submissions for the 2027 World Tax rankings and the 2026 ITR Tax Awards globally
Pillar two was ‘weakened’ when it altered from a multinational convention agreement to simply national domestic law, Federico Bertocchi also argued
Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
Gift this article