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Federal Fiscal Court Issues Two Rulings on the Requirements for a Consolidated Tax Group for Income Tax Purposes - Legal Insights...

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

Finance Ministry Circular on the Tax Recognition of Incongruent Profit Distributions

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

Federal Fiscal Court Confirms Previous Case Law on the Taxation of Management Participations

In its rulings dated December 14, 2023 (VI R 1/21 and VI R 2/21 NV), the Federal Fiscal Court (BFH) confirmed its previous case law on the taxation of management participations and further specified the criteria for...more

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