Germany: New German tax bills impact real estate investment structures and reorganisations

Real Estate Tax Services Newsalert ()

A German tax bill dealing with portfolio investments is expected to be enacted in March. The bill will abolish the participation exemption for dividends received by portfolio investments after 28 February 2013. Further, the Federal Council (Bundesrat) has proposed a new Annual Tax Bill 2013 addressing the use of specific real estate transfer tax (RETT) Blocker Schemes, the use of hybrid instruments, and loss utilisation limitations following reorganisations. The proposed new rules shall have retrospective effect.