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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
The German and international financial industries and their advisors have come under new pressure to investigate so-called 'cum/ex' trades conducted between 2000 and 2012. For many years, tax authorities and criminal...more
Smart Acquisition Structures For Deals In Germany And The UK - What Are the Criteria for Smart Acquisitions via Corporations? - Inbound investment structures seeking to acquire a German or UK corporation should take...more
Arguing that their compensation should count as capital gains — since it derives from the appreciation in value of portfolio companies — private equity executives in Europe generally have been taxed under the more favorable...more