Germany: Sale of bad debts without recourse is not a provision of services

Real Estate Tax Services Newsalert ()

The ECJ has held that the purchase of defaulted debts at a price below their face value and without further recourse to or obligations towards the seller is not a supply of services for a consideration and no economic activity by the purchaser, when the difference between the face value of those debts and their purchase price reflects the actual economic value of the debts at the time of their assignment.

All issues of Real Estate Tax Services Newsalert

Apr 2013 Poland: Step-up in tax base value of real estate assets resulting from changes to the Polish Corporate Income Tax Law
Mar 2013 Spain: Spanish real estate tax updates: REITs, step-up in property values, and other developments
Mar 2013 Germany: New German tax bills impact real estate investment structures and reorganisations
Mar 2013 Germany: Investment advice provided to an investment fund is exempt of VAT
Feb 2013 Germany: German Federal Council plans to end RETT Blocker Schemes with retrospective effect
Feb 2013 OECD - Special Edition: OECD "base erosion and profit shifting" report looks to action plan
Jan 2013 Spain: New Spanish REIT rules approved
Dec 2012 Luxembourg: New tax measures for 2013
Dec 2012 Luxembourg: New tax measures for 2013 - Clarification in relation to the minimum corporate income tax
Dec 2012 AIFMD - Special Edition: AIFMD: the finer details take shape
Dec 2012 Germany: New tax rules for funds and their investors to accommodate the Alternative Investment Fund Managers Directive (AIFMD)
Nov 2012 Germany: Electronic filing of accounts for German tax purposes under the so-called “E-Bilanz” becomes mandatory
Nov 2012 Germany: Germany moves towards implementing the Alternative Investment Fund Managers Directive
Nov 2012 Turkey: Real Estate Transfer Tax increased
Nov 2012 Turkey: Amendment to real estate acquisition limits for foreign citizens
Oct 2012 Spain: New RETT rules on share deals coming
Oct 2012 Germany: German Ministry of Finance plans to end so-called "RETT Blocker Schemes"
Oct 2012 Poland: Changes to the Polish Corporate Income Tax Law
Oct 2012 Sweden: Sweden proposes to reduce the corporate income tax rate to 22% and apply new Interest Stripping Restrictions from 2013
Sep 2012 Netherlands: Extension of real estate transfer tax allowance in case of resale
Aug 2012 Luxembourg: New Luxembourg limited partnership and carried interests provisions
Aug 2012 Spain: Spanish SOCIMI: Proposals to become a real REIT
Aug 2012 Asset management: Real Estate Tax Services Newsalert: Spain passes budget stability guarantees: PwC
Jul 2012 Spain: RETT on share deals: The end of the story?
Jun 2012 Germany/Netherlands: New Double Tax Treaty signed between Germany and the Netherlands
Jun 2012 Poland/Luxembourg: New protocol to the Double Tax Treaty between Poland and Luxembourg
May 2012 Canada: Canadian thin capitalisation limitations tightened
May 2012 Australia: Managed Investment Trust Update
May 2012 Netherlands: New rules for RETT on interests in Dutch real estate entities without legal personality
May 2012 Luxembourg: Luxembourg real estate owning companies – minimum charge to corporate income tax
May 2012 Spain: Tax measures under the new legislation on the restructuring of the real estate portfolios owned by credit institutions
Apr 2012 Spain: Spanish Government approves second round of tax measures aimed at reducing the public deficit
Apr 2012 Germany: New Double Tax Treaty signed between Germany and Luxembourg
Apr 2012 Sweden: New Swedish Interest Stripping Restrictions to apply from 2013?
Mar 2012 Austria: Fiscal Stability Package 2012: Planned Tax Law Amendments in Real Estate Taxation
Mar 2012 Real Estate Tax services Alerts Germany March 2012

Relief from German withholding taxation for non-resident parent entities tightened
Mar 2012 Real Estate Tax services Alerts Germany March 2012 German government suggests 12 tax changes in a newly issued concept paper
Mar 2012 Austria: Fiscal Stability Package 2012: Planned Tax Law Amendments in Real Estate Taxation
Mar 2012 Germany: Relief from German withholding taxation for non-resident parent entities tightened
Feb 2012 France / Luxembourg: Proposed renegotiation of the France-Luxembourg double tax treaty
Feb 2012 United States: Long-awaited proposed FATCA regulations issued
Jan 2012 Ireland: Irish Budget 2012 ― What does it mean for you?
Jan 2012 Spain: New Spanish Government approves measures to reduce public deficit and makes tax amendments for years 2012-2013
Dec 2011 Italy: The new tax regime of Italian Real Estate Investment Funds
Nov 2011 Germany: Sale of bad debts without recourse is not a provision of services
Oct 2011 Germany: New developments on German withholding taxation
May 2011 Spain: German real estate funds: An update on the tax optimization alternatives in Spain
May 2011 Luxembourg: Tax Authorities issue Circulars on Intra-group Financing Activities
Apr 2011 UK: Budget Report 2011
Mar 2011 Netherlands
Feb 2011 Luxembourg: Issue 4
Feb 2011 Spain: Issue 2
Feb 2011 Germany: Issue 1
Feb 2011 France: issue 3
Dec 2010 Germany: Issue 13
Dec 2010 Poland: Issue 12
Jul 2010 Austria: Issue 8
Jun 2010 Italy: Issue 7
Apr 2010 Australia: Issue 6