Germany’s anti-treaty shopping rules are among the most stringent in the world, explain Markus Schümmer and Markus Buchner of Ernst & Young. This was true for the rules that applied up to 2011, and it is still the case for the revised rules that apply from 2012 onward.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year