German Tax Authorities Allow Tax Deductibility Of Additional Tier 1 Capital

Author:Dr. Martin Bünning and Andreas Köster-Böckenförde
Profession:Jones Day
 
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Until very recently, the German tax characterization (debt or equity) of so-called Additional Tier 1 Capital instruments issued under the new regular capital framework for banking institutions (the so-called Basel III framework) was uncertain. On March 13, the German tax authorities announced that they plan to address this issue in a circular that will confirm the debt treatment. This clarification is in line with the practice in a number of...

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