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PKF newsletter 11|2021
Avoiding real estate transfer tax in the case of intragroup restructurings
With regard to the application of the so-called ‘corporate group reservation’ clause (Konzernvorbehalt) under Section 6a of the Real Estate Transfer Tax Act (Grunderwerbsteuergesetz, GrEStG), recently, the German fiscal administration has taken a very much more generous view, when compared with its previous interpretation, of the possibility of exempting specific intragroup restructurings from real estate transfer tax (RETT). In practice, this requires a careful weighing up of the structuring options.
- PKF newsletter 11|2021 Avoiding real estate transfer tax in the case of intragroup restructurings
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