Observation from Kurt Dittrich ofLinklaters Oppenhoff & Rdler

The German Finance Minister, Hans Eichel, has announced plans to clarify a tax issue that has negatively affected securitizations of bank receivables in Germany. Until now it was unclear whether foreign special purpose vehicles (SPVs) that purchase receivables originating from bank loans in securitization transactions are subject to trade tax (Gewerbesteuer) in Germany.

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