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European tax bulletin for Real Estate funds - October 2011


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This bulletin aims to highlight key tax issues which may be of importance to real estate funds and investors.

The October 2011 edition of the European funds bulletin for Real Estate funds includes news on:

  • France:
    • Limitation on the use of tax losses
    • Benefit of participation exemption (PE) regime eroded
    • Partnerships held by non-residents
    • Contribution of assets between SIICs
    • RETT on shares in French or foreign property companies
    • End of tax exemption after 15 years of holding
    • New French 2% Hotel Tax
  • Germany:
    • E-Tax balance Sheet on the way!
    • Decree clarifies application of RETT exemption for intragroup restructurings
    • Federal Tax Court rules on classification of partnership income in German-Hungarian cross-border situation
    • Federal Tax Court rules on applicability of extended trade tax deduction for group companies
  • Greece: Special duty on buildings connected to the electricity network
  • Netherlands: 2012 tax proposals limit interest and loss deductions and codify ruling practice
  • Spain: Changes made to corporate income tax and VAT rules
  • Sweden: Commonplace exit strategies are ruled not to be tax exempt
  • UK: Government’s response to the REITs consultation – HM Treasury updates

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