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Clifford Chance

Clifford Chance


New Rules regarding Restructuring Profits

21 June 2017

After a decision of the Federal Fiscal Court’s Joint Senate was published earlier this year declaring the Restructuring Decree of the tax authorities null and void, there was a lot of uncertainty in the German restructuring practice. The German legislator has reacted unusually fast. The law has already been approved by the Federal Assambly (Bundesrat). It basically converts the Restructuring Decree into law although it has technical flaws. Further, the law will be notified to the European Commission to avoid potential state aid risks and in the meantime the uncertainty remains.

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