- from Dr Frank Thiede
The EU Commission continues to pursue the goal of curbing the abusive use of so-called letterbox companies. After the draft directive (Proposal for a Council Directive...
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ATAD 3 - International participation structures put to the test and DEBRA ante portas?
Transfer pricing: BMF plans further tightening of transfer pricing documentation requirements from 2023
- from TAXGATE
On 12 July 2022, the Federal Ministry of Finance published a draft bill to implement the recently revised EU Mutual Assistance Directive. This contains a tightening of the...
Outbound investments: Tax-neutral capital repayment from foreign corporations - BMF provides clarity
- from Dr Thomas Elser
If a shareholder invests taxed funds in a corporation, the mere redistribution of the investment amounts may not be re-distributed to the shareholder of the corporation.
The dual-resident investor in foreign and income tax law
- from Tobias Stiegler
The tax treatment of investors who are resident in more than one country due to their business activities or their family circumstances is...
Inflow in the event of split appropriation of profits and payment to shareholder-related reserve account
- from Tobias Stiegler
In its ruling of 28 September 2021 (case no. VIII R 25/19), the BFH made a welcome decision and created legal certainty in this respect....
Trade tax relief for property companies - changes due to the Fund Location Act from the 2021 financial year onwards
- from TAXGATE
The Fund Location Act (FoStoG), which came into force on 1 July 2021, provides for various measures to strengthen Germany as a fund location as well as the...
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Transfer pricing: BMF plans further tightening of transfer pricing documentation requirements from 2023
- from TAXGATE
On 12 July 2022, the Federal Ministry of Finance published a draft bill to implement the recently revised EU Mutual Assistance Directive. This contains a tightening of the...
Outbound investments: Tax-neutral capital repayment from foreign corporations - BMF provides clarity
- from Dr Thomas Elser
If a shareholder invests taxed funds in a corporation, the mere redistribution of the investment amounts may not be re-distributed to the shareholder of the corporation.
The dual-resident investor in foreign and income tax law
- from Tobias Stiegler
The tax treatment of investors who are resident in more than one country due to their business activities or their family circumstances is...
Inflow in the event of split appropriation of profits and payment to shareholder-related reserve account
- from Tobias Stiegler
In its ruling of 28 September 2021 (case no. VIII R 25/19), the BFH made a welcome decision and created legal certainty in this respect....
Trade tax relief for property companies - changes due to the Fund Location Act from the 2021 financial year onwards
- from TAXGATE
The Fund Location Act (FoStoG), which came into force on 1 July 2021, provides for various measures to strengthen Germany as a fund location as well as the...
Partnership opting for corporation tax as a controlled company?
- from Dr Wolfgang Walter
From 2022, a partnership can be taxed like a corporation (KöMoG of 30 June 2021, Federal Law Gazette I 2021, 2050). The way...
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