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The latest news and information worth using from taxes, law, accounting and business management new every month.

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. 


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