MiFID II has introduced a set of new requirements for investment firms as “producers” of investment products and for placement agents as “distributors” of such products. Most of the requirements set forth in MiFID II are provided in connection with retail clients. However, certain requirements also apply when dealing with professional clients.
With the German investment tax reform come many changes. In addition to dividend and real estate income, there is one other form of taxable income that, until now, has been not been in the center of attention as much: other German source income. Our beinformed demonstrates that this income surprisingly may include foreign source income too.
With its decision dated 30 May, 2017, the German Federal Fiscal Court referred to the European Court of Justice (“ECJ”) several questions on the potential state aid qualification of the tax exemption according to Sec. 6a of the German Real Estate Transfer Tax Act. This provision – under specific circumstances – exempts group restructurings involving property holding companies, which as such generally qualify as a taxable acquisition under the German Real Estate Transfer Tax Act, from taxation.