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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Pillar two might be top of mind for many multinational companies, but the huge variations between countries’ readiness means getting ahead of the game now, argues Russell Gammon, chief solutions officer at Tax Systems.