Special features - February 2015

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Special features - February 2015

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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

Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Awards
Submit your nominations to this year's WIBL Americas Awards by January 23
Recent changes in UK tax rules and cross-border requirements are generating high demand for specialist advice, according to MHA
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default
EY, KPMG, Deloitte, and PwC have all seen a decrease in public sector contracts since the scandal – it is understood
Consoli, a tax partner at Brazilian law firm Martinelli Advogados, tells ITR about the importance of staying at the coalface and constantly learning
Despite legislative gridlock, international investors should be wary of legal precedents set by recent court rulings, which could substantially alter the Spanish tax environment
The new outfit, Ashurst Perkins Coie, will bring together around 3,000 lawyers across 23 countries
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