After assisting with several tax audits for various clients in the real estate sector, Patrick Bubeck and Dr Tobias Stiegler are currently working on a...
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Outbound investments: Tax-neutral repayment of capital from foreign corporations - Federal Ministry of Finance creates clarity
If a shareholder invests taxed funds in a corporation, the mere re-distribution of the investment amounts must not be subject...
ECJ and BFH abandon case law: No deduction of so-called final foreign permanent establishment losses
In its ruling of 22 February 2023, the Federal Fiscal Court (BFH) made an important and final decision for German companies operating internationally: According to this...
Equity and debt capital are treated completely differently for tax purposes; in particular, interest on operating debt capital is tax-deductible, while dividends from equity and debt capital are...
A typical case of application of exit taxation pursuant to Section 6 AStG is a taxpayer resident in Germany with a significant shareholding in a...
After a long period of record low interest rates, the era of cheap money is definitely over. The steep rise in interest rates in recent...
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Growth Opportunities Act: Partnerships (finally) receive a sensible retention option (Section 34a EStG as amended)
More than 15 years after the introduction of the regulation with the creation of a two-stage special rate for retained profits of partnerships preparing balance sheets, the...
We also recommend that you take a look at your transfer pricing landscape at the end of 2023 in order to take any necessary measures in good time for the current...
In the context of medium and long-term capital and tangible assets, the GmbH offers a number of advantages compared to direct investments in...
An upside-down world: The healing of an income tax group threatened with failure is generally regarded as desirable. However, the Federal Fiscal Court's...
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