Oliver Staatz

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Tightening of German Real Estate Transfer Tax Rules for Share Deals

The Situation: Under the German real estate transfer tax ("RETT") law, RETT is not only triggered on the direct acquisition of German properties, but also in case of share deals involving companies with German properties, if...more

6/11/2019 / Germany , Investors , New Rules , Partnerships , Popular , Real Estate Transfers , Realty Transfer Taxes , Regulatory Agenda , Stock Transfer , Transfer Taxes

German Profit and Loss Transfer Agreements Face Deadline to Protect Consolidated Tax Treatments

Existing contracts must be amended no later than December 31, 2019. Parties to certain older German profit and loss transfer agreements ("PLTA"), take note. According to the German Federal Ministry of Finance's ("BMF")...more

5/23/2019 / Corporate Taxes , Germany , International Tax Issues , Limited Liability Company (LLC) , Lost Profits , Ministry of Finance , Parent Corporation

EU Targets Tax Avoidance Reporting Obligations for Intermediaries

The Situation: The Member States of the EU have unanimously agreed on a proposed directive establishing new and far-reaching tax reporting obligations for "intermediaries" and taxpayers. The Result: The proposal lays down...more

4/3/2018 / BEPS , Cross-Border , EU , Intermediaries , Legislative Agendas , Member State , OECD , Reporting Requirements , Tax Avoidance , Tax Planning

German Constitutional Court Held Parts of Loss Forfeiture Rules are Unconstitutional

The German Constitutional Court held that a provision of the loss forfeiture rules, in effect from January 1, 2008, through December 31, 2015, is unconstitutional. The provision stipulates a proportional forfeiture of current...more

7/11/2017 / Business Taxes , Constitutional Challenges , Constitutional Courts , Equity Transactions , Germany , Grace Period , Loss-Carryover , Loss-Forfeiture , Repeal , Tax Assessment

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