Following to tax advices of several tax audits in the German real estate sector, Patrick Bubeck and Dr Tobias Stiegler...
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Taxation of asset-managing real estate partnerships in a group of companies
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...
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...
Hybrid financing: New BMF circular on the tax treatment of profit participation capital
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...
BFH: Exit taxation and "merely temporary absence"
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...
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