International investors typically use foreign holding companies for investments in German companies or assets such as real estates (so-called inbound...
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Federal Fiscal Court: Limited Tax Liability of Foreign (Holding) Companies / Managing Directors as Permanent Representatives in Germany
Business split - opportunities and risks for avoiding the "colouring" of asset management income by the BFH ruling of 12.04.2018 - IV R 5/15
A business split is defined as the division of the functions and assets of a legally and economically uniform business into two companies, one of which...
BFH on the tax liability of a foreign corporation due to the managing director's activities in Germany
Foreign (holding) corporations are used by German investors to make investments and capital investments abroad (so-called outbound investments), but also by German investors who...
Düsseldorf tax court on distribution in kind through allocation of new shares (here: spin-off: Hewlett-Packard in 2015)
In a letter dated 20 March 2017, the German Federal Ministry of Finance classified the allocation of new shares as part of the spin-off of Hewlett-Packard Incorporated as a taxable...
Profit transfer agreement and fiscal unity personally dangerous for the managing director?
In its judgement published on 10 April 2019 (case reference I R 78/16), the Federal Fiscal Court (BFH) confirmed the controversial legal opinion that the creation of provisions...
TAXGATE partner Dr Wolfgang Walter now co-editor of Bott/Walter, KStG commentary from Stollfuß-Verlag
The consolidated tax group for corporation and trade tax purposes is one of the most common and proven structures in corporate tax law for decades. The most important advantages of this...
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