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The tax treatment of reorganisation-induced additional transfers in the case of a consolidated tax group

It is the view of the fiscal administration that a merger within an existing consolidated tax group structure at fair market values under German […]

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Cross border group financing – An update on the arm’s length nature

The Federal Fiscal Court’s (Bundesfinanzhof, BFH) ruling on interest rates for shareholder loans has been a subject covered in our previous articles […]

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The ‘royalty barrier’ rule – BMF sets out the requirements for preferential regimes

Since the introduction of the ‘royalty barrier’ rule (Section 4j of the German Income Tax Act), limits have been placed on the tax deductibility of […]

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The size effect in business valuation – The causes and risks of higher-than-average returns from small companies

In the context of business valuation, it is always noticeable that, when compared with large companies, small companies generate higher-than-average […]

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Fines for employers for infringing documentary evidence requirements

As part of the implementation of EU Directive 2019/1152 on working conditions, the Act on Notification of Conditions Governing an Employment […]

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Outstanding issues related to the recapitulative statement

The Federal Ministry of Finance (Bundesministerium der Finanzen, BMF) has once again adjusted the German VAT application decree on the tax exemption […]

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Property purchases – New guideline for the apportionment of the purchase price

Those who buy rental properties are generally interested in allocating as high a share of the purchase price as possible to the building because only […]

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Compensation for flight delays between third countries

If a flight is delayed then an airline from the EU has to pay compensation to its passengers if the delay exceeds a certain amount of time. The ECJ […]

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Add-backs for rental charges for trade fair stand space for trade tax purposes

Recently, the Federal Fiscal Court (Bundesfinanzhof, BFH) decided that rental charges for trade fair stand space that a company rents for exhibition […]

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Obligation to provide proof of the value of the stake in a company that has been gifted

Recently, the Munich tax court had to rule on the obligation to provide proof of the calculation of the value of the stake in a company that have been […]

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