Abstract

In the referendum held on 23 June 2016, the British people voted to leave the European Union (EU). Whereas the economic impact of ‘Brexit’ is being discussed extensively, its tax implications have not yet been the focus. It is obvious that ‘Brexit’ will end the UK’s membership in the Customs Union as well as the UK’s participation in the harmonized European system for value-added taxes and excise duties. Less obvious is the impact of ‘Brexit’ on certain provisions of German national tax law that link preferential treatment to EU or European Economic Area membership: ‘Brexit’ will change the tax treatment of German-based shareholders and beneficiaries of UK businesses, companies, trusts, and foundations for the worse.

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