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New tax decree concerning German Anti Avoidance Rule section 50d para 3 German Income Tax Act (April 2018)

Client Briefings

The Federal Ministry of Finance has published a new tax decree dealing with the interpretation of the German substance requirements pursuant to section 50d para 3 German Income Tax Act.

In order to assess whether relief from withholding tax exists, the tax authorities shall consider group structure and strategy concepts as acceptable arguments

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