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Corporate Taxes Intra-Group Transactions

Hogan Lovells

Double standards for the taxation of intra-group financing

Hogan Lovells on

The German Federal Ministry of Finance has published a draft law for the implementation of the EU Anti-Tax Avoidance Directive (ATAD Implementation Act) on 10 December 2019. This draft includes inter alia a new section 1a...more

BakerHostetler

Proposed Regulations Would Fundamentally Change Treatment of Intra-Group Debt Transactions

BakerHostetler on

On April 4, 2016, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued two sets of regulations, temporary regulations addressing “inversion” transactions and proposed regulations regarding the...more

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