Globale Mindeststeuer Setzt Neue Leitplanken

Germany's advance lump-sum taxation regime imposes annual deemed investment income on German tax-resident investors in qualifying investment funds, regardless of distributions.

German tax residents must report worldwide income on their tax returns, including rental income from foreign properties and investment earnings from abroad.

When a German employer hires foreign EU workers for a short-term project without proper tax and social security documentation, what appears to be a cost-effective staffing solution can quickly transform into a financial burden. Through a detailed case study and sample calculations, this analysis reveals how routine audits can expose compliance gaps that nearly double the actual employment costs.

Germany's Annual Tax Act 2024 (Jahressteuergesetz) brings tweaks to the country's Income Tax Act (Einkommensteuergesetz). Due to adjustments to Sec. 22 no. 5 sentence 2 of the act...

The Fiscal Court of Münster has ruled on a critical question in German reorganization tax law: when assessing whether a contribution in kind qualifies for tax-neutral treatment, should authorities examine the circumstances on the actual contribution date or the retroactive tax effective date? This decision challenges longstanding administrative guidance and could fundamentally reshape how businesses structure tax-efficient reorganizations involving partnership interests and special business assets.

The German Federal Constitutional Court is set to rule on the constitutionality of Section 8c of the Corporate Tax Act, which mandates complete forfeiture of tax losses when more than 50% of a corporation's shares change hands. The Hamburg Fiscal Court has supplemented its 2017 referral order with new details about a specific case where losses would be forfeited solely due to share acquisition, raising fundamental questions about whether this provision violates Germany's constitutional principle of equality

Corporate transactions in Germany present complex tax considerations for buyers and sellers, with fundamentally different implications depending on whether the deal is structured as an asset or share transaction. Understanding how capital gains taxation, real estate transfer tax, and depreciation rules apply to each structure is essential for optimizing after-tax outcomes and managing inherited tax liabilities.

Germany has enacted significant reforms to its real estate transfer tax rules for share deals, addressing the controversial issue of double taxation that previously arose when signing and closing occurred at different times. The new legislation establishes a clear hierarchy between tax provisions and extends notification periods, fundamentally changing how M&A transactions involving real estate-owning companies are taxed.

The following case involves Germany on one side, but this example may be applicable for many other jurisdictions.

On 21 July 2015, the German Federal Ministry of Finance released a discussion draft for a proposed German Investment Tax Reform Act.

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement...

On 30 September 2021, the Ministry of Industry and Information Technology (MIIT) circulated for public comment the Measures on the Administration of Data Security in the Industry and Information Technology Sector

On December 18, 2025, President Trump signed into law the BIOSECURE Act as part of the National Defense Authorization Act (NDAA), which is the U.S. Congress's annual defense policy bill.

Japan is widely perceived as one of the least corrupt countries in the world. In 2020, Transparency International ranked Japan as the 19th least corrupt country out of 180 countries in...

A recent proposal issued by Japan's ruling Liberal Democratic Party, along with various other current private- and public-sector initiatives, signals a strong interest in promoting investment in and the growth...

On May 27, 2019, the Japanese government published amended rules[1] that aim to tighten the regulatory requirements applicable to foreign direct investment (tai nai chokusetsu toshi or FDI)

The new Enterprise Bankruptcy Law of the People’s Republic of China (PRC) (Bankruptcy Law) was adopted on August 27, 2006 and will take effect on June 1, 2007, superseding the 1986-enacted Enterprise Bankruptcy Law (Trial) 1986, governing the bankruptcy of State-owned Enterprises . The Bankruptcy Law offers for the first time a unified regime applicable to all types of enterprises in China and also provides a more robust and detailed regime for enforcement of creditors’ claims. We discuss below

On June 30, 2017, the Wuhan Intermediate People's Court (the "Wuhan Court") issued a decision recognizing and enforcing a civil money judgment issued by the Los Angeles Superior Court arising out of...

On 25 July 2018, the European Commission ("the Commission") published its decision on the Altice/PT Portugal gun jumping case. The Commission concluded that various contractual clauses allowed Altice N.V. ("Altice") ...

Like the COVID-19 virus, COVID-related contract claims have not gone away. In "Contracting in the Fog of War: Recovering Costs Caused by an Epidemic," we reported on Pernix Serka Joint Venture v. Department...