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Investor Presentaiton

Proposed tightening of German Real Estate Transfer Tax Rules 建议收紧德国房地产转让税务规则 RETT Reform on the horizon for share deals RETT ΔΙΔ Tightening of the RETT rules has been subject to discussion since 2019. It seems that the legislative process which was pending for a couple of months is becoming active again • • Based on a draft bill published on 30 July 2019, the proposed amendments of the RETT Act mainly include tightened rules on the taxation of share deal transactions involving German real estate The key aspects of the proposed RETT Reform are mainly in line with the discussion/first draft published in September 2018/May 2019 and include: Reduction of the RETT triggering threshold from 95% to 90% for share deals as well as transactions involving partnerships (while RETT applies to 100% of the property value) • Extension of the minimum holding periods for transfers of interests in partnerships from 5 to 10 years • Extension of the so-called retention/monitoring periods for certain exemptions for partnerships from 5 to 10 years • Extension of the so-called "partnership transfer rules" to share transfers in corporations, which could add significant additional complexity to the RETT rules (no exemption for publicly traded companies!) • At the moment it seems that there is no political consensus. There are discussions of decreasing the RETT triggering threshold further. _ 30 July 2019 Issue of first draft of the RETT Reform Bill © 2021. For information, contact Deloitte China. Today Still no final draft law 21
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