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Germany: Legislation to implement ATAD includes exit tax, CFC rules, hybrid mismatch provisions

Germany: Legislation to implement ATAD

A draft bill to implement the anti-tax avoidance directive (ATAD) includes measures concerning:


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  • Exit taxation
  • Controlled foreign corporation (CFC) rules
  • Hybrid mismatches

In addition, the legislation would adjust a provision of German law to more closely align with the OECD’s transfer pricing guidelines.

Read a January / February 2020 report [PDF 355 KB] prepared by the KPMG member firm in Germany

The KPMG report also includes brief descriptions about:

  • A Federal Tax Court (BHF) case concerning interpretation of the OECD model tax convention
  • A lower tax court of Lower Saxony case concerning trade tax add-backs when renting a trade fair stand
  • Guidance from the Frankfurt regional tax office on recognition of a consolidated tax group with a corporation founded in another EU / EEA country (other than Germany)

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