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1.1 Enactment of Tax Reform 2000
1.2 Content and basis of this article
1.3 Key features unchanged
1.4 Revenue-generating measures
1.5 Entry into force
Part II. Taxation Of Corporations
2.1 New corporation tax system
2.2 Effective dates
2.2.1 25 % corporation tax rate
2.2.2 Capital gains exemption - § 34 (6d) no. 2 KStG
2.2.3 Dividends and dividends-received exemption - § 34 (6d) no. 1, (10a) KStG
2.2.4 Capital losses and share writedowns - § 34 (6d) no. 2 KStG
2.3 Transition period
2.4 New uniform corporate tax rate
2.4.1 General
2.4.2 German permanent establishment
2.4.3 German subsidiary - retained earnings
2.4.4 German subsidiary - distributed earnings
2.4.5 Effect of higher or lower trade tax multiplier
2.4.6 Summary
2.5 Dividends-received exemption - § 8b (1) KStG
2.5.1 General
2.5.2 Domestic dividends: § 3c EStG
2.5.3 Foreign dividends: § 8b (7) KStG
2.5.4 CFC provisions
2.6 Capital gains exemption - § 8b (2) KStG
2.7 Permanent establishments
2.8. Reorganizations
2.9 Depreciation rule changes
2.9.1 Declining balance depreciation
2.9.2 Non-residential buildings used in a business
2.9.3 General tax depreciation tables
2.9.4 Limitation on anticipated special depreciation - § 7g EStG
2.10 Thin capitalization rules - § 8a KStG
2.10.1 Changes
2.10.2 Entry into force
2.10.3 Diminished incentive for foreign debt financing ?
2.10.4 Doing business in branch form?
2.10.5 Arm's length exception
2.10.6 Pitfall no. 1 for holding structures
2.10.7 Pitfall no. 2 for holding structures
2.11 Dividend stripping
2.12 Loss utilization and tax consolidation
2.12.1 Loss utilization with corporation tax credit
2.12.2 Need for tax consolidation after the new legislation
2.12.3 Relaxed requirements for corporation tax consolidation
2.12.4 Trade tax and VAT consolidation
2.13 CFC provisions
2.13.1 General
2.13.2 Conflict with EU law?
2.13.3 Other changes in the CFC rules
2.14 Eurowings
2.15 More German foreign investment?
Part III. Taxation Of Individuals
3.1 Income tax rate changes
3.2 50 % exemption system - § 3 no. 40 EStG
3.2.1 50 % exemption system in general
3.2.2 Holding periods
3.2.3 Entry into force - § 52 (4a) EStG
3.2.4 Limit on deductions - § 3c (2) EStG
3.2.5 No limit on credit of foreign taxes - § 34c EStG
3.3 Sales of businesses and corporate stock - §§ 16 and 17 EStG
3.4 Threshold of § 17 EStG lowered to 1 %
3.4.1 Present and future law
3.4.2 Impact on domestic and foreign shareholders
3.5 Shift from corporation tax credit to exemption system
3.6 Other changes in the Income Tax Act
3.7 Trade tax relief: elimination of "elective regime"
3.8 Trade tax relief: basic regime
Part IV. Changes In Other Tax Laws
4.1 Changes in the Tax Procedure Act (AO)
4.2 Changes in the Value Added Tax Act (UStG)
4.3 Changes in the Investment Companies Act (KAGG) and Foreign Investment Act (AuslInvestmG)
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