The German Federal Ministry of Finance on December 10 circulated for consultation purposes a draft bill providing for the implementation of ATAD in Germany. The draft bill in particular includes the implementation of anti-hybrid rules into German tax law, as well as the amendment of existing German CFC rules.
The draft legislation on ATAD implementation in Germany should be considered by all German taxpayers, particularly those that are part of multinational groups. Taxpayers should consider whether and how these rules might impact them. Taxpayers should monitor the legislative process, since it currently remains unclear as to whether the draft version of the rules will be subject to (significant) change.