The planned disclosure requirement for domestic tax arrangements and its potential impact on German funds

Surprisingly, the government draft of the Tax Reform Act again contains proposals for the introduction of a notification obligation for domestic tax arrangements. The proposed § 138l - § 138n AO-E were taken over with identical wording from the failed draft of the Growth Opportunities Act. This article examines the possible consequences of the introduction of a reporting obligation for domestic tax arrangements for German funds, their managers and investors.