Double standards for the taxation of intra-group financing

The German Federal Ministry of Finance has published a draft law for the implementation of the EU Anti-Tax Avoidance Directive (ATAD Implementation Act) on 10 December 2019. This draft includes inter alia a new section 1a German Foreign Tax Act (Außensteuergesetz – AStG) on cross-border intra-group financing.

This article explores how the implementation of this proposal would further increase the legal uncertainty in this area.


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