Germany: Interested parties
Earlier this month, the German Corporate Tax Reform 2008 secured the approval of all Germany's legislative bodies and will become effective on 1 January next year. The Corporate Tax Reform 2008 does not provide for any 'grandfather clauses' for current transactions but for structures involving German entities with deviating fiscal years, the changes might already have an impact on fiscal years starting in 2007. The reform can be divided into two key elements: firstly, the intended reduction of an overall tax rate for corporations (corporate and trade tax) from 38.6% to slightly below 30%; and secondly a new general interest deduction limitation rule - the new rule - which will have a significant impact on leveraged transactions in Germany.
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