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Business restructuring troubles taxpayers in Germany

July 21, 2009

Werner Stuffer and Jörg Hanken of PricewaterhouseCoopers discuss German business restructuring regulations and how the economic crisis affects this area of tax planning.

As of 2008 German rules regarding business restructurings and the arm's-length principle itself were enacted as section 1 III of the German Foreign Tax Act (Außensteuergesetz) . A business restructuring ordinance law (Funktionsverlagerungsverordnung (FVerlV)) was published on August 12 2008 as well, to explain the background, the applicable cases and evaluation aspects of business restructurings in more detail.

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