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- Title
Neuregelungen zu grenzüberschreitenden Finanzierungsbeziehungen und Finanzierungsdienstleistungen in einer Unternehmensgruppe durch das Wachstumschancengesetz (§ 1 Abs. 3d und 3e AStG) – Teil 1.
- Authors
Grotherr, Siegfried
- Abstract
The article "New regulations on cross-border financing relationships and financing services within a corporate group through the Growth Opportunities Act (§ 1 para. 3d and 3e AStG) - Part 1" deals with the new regulations on the transfer of intangible assets and cross-border financing transactions within multinational corporate groups. Originally, it was planned to introduce an interest rate cap to limit the tax-deductible interest expenses in external financing relationships. However, due to criticism from associations, this plan was abandoned. Instead, the principle of arm's length and the examination of arm's length conformity are now specified. The article also sheds light on the reasons for not introducing the interest rate cap. The Federal Council has expressed concerns that financial jurisprudence is not bound by the recommendations of the OECD and that the interest rate cap would represent a significant burden for companies. The Finance Committee of the German Bundestag plans to replace the interest rate cap with new regulations that are intended to interpret the arm's length principle in cross-border financing relationships within a group.
- Subjects
INTEREST rates; GERMANY. Bundestag; INTANGIBLE property; CONFORMITY; JURISPRUDENCE; COST
- Publication
Die Unternehmensbesteuerung (Ubg), 2024, Vol 17, Issue 5, p241
- ISSN
1865-7222
- Publication type
Article
- DOI
10.9785/ubg-2024-170501