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* Once an acquirer (Vonovia) amass 90% voting rights in the target (Deutche Wohnen), a real estate tax (RETT) is triggered. The tax rate ranges from 3.5% to 6.5% in Germany. In Berlin, where Deutsche Wohnen has its most properties, the tax rate is 6.5%. The tax is based on the purchase price of shares (without VAT) or real estate value in case of a lack of assessable consideration<ref>https://www.pwc.com/gx/en/financial-services/publications/assets/pwc-real-estate-transfer-tax.pdf</ref>. | * Once an acquirer (Vonovia) amass 90% voting rights in the target (Deutche Wohnen), a real estate tax (RETT) is triggered. The tax rate ranges from 3.5% to 6.5% in Germany. In Berlin, where Deutsche Wohnen has its most properties, the tax rate is 6.5%. The tax is based on the purchase price of shares (without VAT) or real estate value in case of a lack of assessable consideration<ref>https://www.pwc.com/gx/en/financial-services/publications/assets/pwc-real-estate-transfer-tax.pdf</ref>. | ||
* Since Vonovia already has 87% stake in Deutsche Wohnen, it only needs 3% to cross the 90% threshold for RETT<ref>https://www.jonesday.com/en/insights/2019/06/tightening-of-german-real-estate</ref>. | * Since Vonovia already has 87% stake in Deutsche Wohnen, it only needs 3% to cross the 90% threshold for RETT<ref>https://www.jonesday.com/en/insights/2019/06/tightening-of-german-real-estate</ref>. | ||
* Companies that have held 95% stake in another company for at least 5 years can transfer their shares to another entity as part of internal group restructuring such as a merger and claim RETT exemption. The entity holding 95% stake should also continue to have a controlling interest 5 years after the merger<ref>https://www.taxathand.com/article/30066/Germany/2023/Updated-guidance-published-on-RETT-intragroup-restructuring-exemption</ref>. | |||
== Past DPLTA Real Estate Actions In Germany == | == Past DPLTA Real Estate Actions In Germany == |