Group Financing: From Thin Capitalization to Interest Deduction Limitation Rules

Journal
International Transfer Pricing Journal 2009 (Volume 16), No. 1
This article discusses the evolution of thin capitalization rules in Germany and the European Union. Topics addressed include jurisprudence of the European Court of Justice; past and present German rules on the tax treatment of interest expense, including the new interest deduction limitation rules; and criticism to date of the new German rules.