In two rulings, the Federal Fiscal Court (BFH) ruled in favor of the taxpayer on the requirements for a consolidated tax group for income tax purposes. Managing holding partnership as controlling company (judgment of November...more
In its decision dated February 26, 2025 (7 K 1811/21 K), the Düsseldorf Fiscal Court concluded that legal and consulting fees incurred by the indirect sale of a second-tier subsidiary by the subsidiary are deductible business...more
The German Federal Fiscal Court (BFH) confirmed its case law according to which the commercial infection of an upper-tier partnership pursuant to Section 15 para. 3 no. 1 sentence 1 alt. 2 German Income Tax Code...more
Due to the end of the so-called traffic light coalition and the upcoming new elections in Germany, numerous draft tax bills will not be adopted prior to the end of this legislative period. However, the Annual Tax Act 2024 was...more
In several recently published rulings, the German Federal Fiscal Court (BFH) has commented on several aspects of real estate transfer tax (RETT) in case of share deals—also contrary to the previous opinion of the tax...more
2/19/2025
/ Acquisitions ,
Business Entities ,
Corporate Taxes ,
Partnerships ,
Property Tax ,
Real Estate Investments ,
Real Estate Transactions ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Transfer Taxes
In its ruling dated September 28, 2022 (VIII R 20/20), the Federal Fiscal Court (BFH) decided, contrary to the previous opinion of the tax authorities, that a resolution on an incongruent distribution of a limited liability...more
The German legislator is currently introducing a large number of tax law changes in various draft bills. This article provides an overview of the most important planned changes. The draft Annual Tax Act 2024 (JStG 2024)...more
As part of the legislative process, the Federal Council (Bundesrat) convened the Mediation Committee at the end of November 2023.
For this reason, some regulations that were initially provided for in the Growth Opportunities...more