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Nutzen deutsche Konzerne Belgien als Finanzierungsstandort?: Eine Fallstudie

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Abstract

Belgien ermöglicht es Unternehmen einen Eigenkapital-Zinsaufwand steuerlich zu berücksichtigen. Dies eröffnet multinationalen Konzernen die Möglichkeit, Gewinne in belgische Finanzierungsgesellschaften zu verlagern und dort praktisch zum Nulltarif zu versteuern. Diese Fallstudie stellt zunächst dar, wie eine solche Finanzierungsgesellschaft aufgesetzt werden kann. Anschließend wird mittels eines einzigartigen Datensatzes untersucht, inwieweit DAX und MDAX Konzerne Steuerplanung mittels Finanzierungsgesellschaften in Belgien betreiben. Es werden sieben Finanzierungsgesellschaften identifiziert; sieben weitere Konzerne betreiben möglicherweise eine operativ tätige Finanzierungsgesellschaft. In einem weiteren Schritt wird approximiert, dass jährlich Gewinne in Höhe von 914 Mio. € verlagert und dadurch Steuern in Höhe von 179–242 Mio. € gespart werden. Für diesen Datensatz wird ein Steueraufkommensverlust für Belgien aufgrund des Eigenkapital-Zinsaufwands in Höhe von 11–36 Mio. € jährlich geschätzt.

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