• Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 8/6/2014

Germany - Excess transfers in tax groups, going-concern value write-downs 

August 6: The German federal tax court (BFH) and a lower court issued decisions concerning:
  • The treatment of excess transfers among members of tax groups, relating to a pre-tax group period
  • Write-downs of a lower going-concern value of loans to a foreign subsidiary
  • “Futile” expenses for setting up a fixed place of business (permanent establishment) in a third county, held not deductible in Germany if the exemption method applies

Read an August 2014 report prepared by the KPMG member firm in Germany: German Tax Monthly (August 2014)

Other topics discussed in this KPMG report concern:

  • e-Balance sheet – Publication of taxonomy version 5.3
  • Changes in the taxation of income of deemed commercial partnerships
  • FATCA implementation ordinance

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