European Tax Bulletin For Real Estate Funds: May 2012



This bulletin aims to highlight key tax issues which may be of importance to real estate funds and investors.

Key findings

The May 2012 edition of the European funds bulletin for Real Estate Funds includes news on:


Tax authorities lose another beneficial ownership case Finland

EBITDA-based limitation on related party interest proposed France and Germany:

"Green Book" on tax convergence published / German coalition parties announce further business tax reform Germany:

BMF issues guidance on amended anti-treaty shopping rule Official guidance issued on Reorganisations under Reorganisation Tax Act New case law on capital gains taxation upon transfer of assets to foreign PE Guidance issued on income tax treatment of RETT triggered upon transfer of a partnership or corporation BFH rules on set off of loss carryforwards against profits derived in year of harmful change-in-ownership Draft Taxation Act 2013 incorporates the authorised OECD approach to taxing PEs Federal tax court clarifies scope of participation exemption UK:

2012 Budget - implications for real estate Consultation launched on income tax rules on interest Italy:

Real Estate Investment...

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