Stephan Eilers and Alexander Schwahn of Freshfields Bruckhaus Deringer provide a brief overview of a classic structure for a private equity investment in Germany, and they critically analyse the efforts of both the tax authorities and the legislature to place restrictions on debt push-down structures.
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Arindam Mitra and Robin Hart examine how aggregate TP rules clash with transaction-level customs rules, creating compliance risks and requiring granular, SKU-level pricing strategies
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals