German Tax Monthly January/February 2025

KPMG's German Tax Monthly is an English-language publication appearing once a month in PDF-format. German Tax Monthly provides useful information regarding the latest tax developments in Germany and focuses on foreign investors. Selected topics which are of interest in the daily business of international companies are summarized in a user-friendly manner.   

This issue contains articles on the following topics:

• the Promulgation of the Tax Haven Defence Regulation 2024,
• the Promulgation of the Tax Development Act,
• the Government Draft Bill for a Second Future Financing Act,
• the Revised Draft Law Proposing Amendments to the Minimum Tax Act,
• the Judgement of the Lower Tax Court of Düsseldorf on the German CFC Rules, in particular the Functional Approach and the Violation of the Free Movement of Capital in Third-Country Cases,
• the Guidance on the Application of the Anti-Hybrids Rules,
• the Guidance on the Motive Test in the context of the German CFC Rules Old Version and
• the Guidance on the Administrative Principles on Transfer Pricing 2024.