ドイツ結合組織体課税制度改訂への決意表明の背景

概要

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Although the German fiscal unity taxation system (Organschaft) was not amended by the 2009 Accounting Law Modernization Act (BilMoG) by which the reverse authority of tax accounting in regard to financial accounting was abolished, the German coalition government presented to the national parliament in February 2012 a paper entitled "12 points to further modernize and simplify the taxation of businesses", in which the main message was that the Organschaft should be replaced as of 2016 with a new modernized one. In this paper, I attempt to clarify the background and the reason why the Organschaft was not amended by the BilMoG and why in early 2012 it was announced that it would be replaced with a new modernized one as of 2016.