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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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
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