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

The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity
Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR
AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said
In a post on X, Scott Bessent urged dissenting countries to the US/OECD side-by-side arrangement to ‘join the consensus’ to get a deal over the line
A new transatlantic firm under the name of Winston Taylor is expected to go live in May 2026 with more than 1,400 lawyers and 20 offices
As ITR’s exclusive data uncovers in-house dissatisfaction with case management, advisers cite Italy’s arcane tax rules
The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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