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BFH considers 5. Still available options for implementing restructurings without triggering RETT should be made use of.

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A provision that may result in insurance premium payments made by a nonresident to an insurer in a third country being subject to tax in Germany—even in the case of intragroup contributions—increasingly is becoming the focus of tax audits. Court decides rules violate EU law for all payments triggering withholding tax, regardless of whether a reduced rate applies based on an EU directive or an applicable tax treaty.

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Several recent tax audits have shown an increased interest from tax inspectors in business expenses incurred for online advertising. European Commission considers German exit tax rules oogin capital gains taxation too restrictive in relation to EEA member states.

Deviation from the previous interpretation of Section a 1 German Civil Code in the case of opened insolvency proceedings: Decision of ECJ could substantially increase the risk of additional costs for the purchaser. Lower tax court of Baden-Wuerttemberg considers CFC income exempt from trade tax in years up to and including FY 15, and questions whether subjecting such income to datinv tax in subsequent years is compatible with EU law.

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