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Modern skyscrapers of the European Court of Justice in Luxembourg with waving EU member state flags against a blue sky.

ECJ and BFH abandon case law: No deduction of so-called final foreign permanent establishment losses

In its judgement of 22 February 2023, the Federal Fiscal Court (Bundesfinanzhof, BFH) clarified a significant and important issue for German companies operating internationally, in particular corporations such as...

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...

Rising interest rates and transfer prices

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...

Significant improvement for the departure to third countries in the case of shares born on contribution

Conversions under the UmwStG 1995 could lead to so-called contribution-born shares. The legal principles at that time were temporally amended with the UmwStG 2006...

TAXGATE strengthens team in Stuttgart with two additional Senior Managers

Ilkan Dadusut, a highly experienced tax consultant, will join the company on 1 April 2023 after working for PwC and Baker Tilly....

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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...

Rising interest rates and transfer prices

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...

Significant improvement for the departure to third countries in the case of shares born on contribution

Conversions under the UmwStG 1995 could lead to so-called contribution-born shares. The legal principles at that time were temporally amended with the UmwStG 2006...

TAXGATE strengthens team in Stuttgart with two additional Senior Managers

Ilkan Dadusut, a highly experienced tax consultant, will join the company on 1 April 2023 after working for PwC and Baker Tilly....

Art as a capital investment - ARTEX Kunstbörse

The Financial Market Authority recently granted ARTEX AG final approval to establish an art exchange with a trading centre in Liechtenstein....

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