The German government has once again proposed to limit participation exemption to dividends that have not been deducted at the distributing entity level. The measure may force taxpayers to reassess the pricing of hybrid instruments.
Unlock this article.
The content you are trying to view is exclusive to our subscribers.
Two months since EU political agreement on pillar two and few member states have made progress on new national laws, but the arrival of OECD technical guidance should quicken the pace. Ralph Cunningham reports.