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  • Article

    Old System Corporation Tax Refund To Foreign Shareholder Is A Dividend - Supreme Tax Court

    The Supreme Tax Court has confirmed the provisions of the Corporation and Income Tax Acts subjecting corporation tax refunds to foreign shareholders to treaty rate dividend withholding tax.
    GermanyFinance and Banking
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    Proposed Extension Of VAT Exemption For Management Of All Alternative Investment Funds (AIFs)

    On 4 April 2023, the German Federal Ministry of Finance and the German Federal Ministry of Justice announced a draft bill for an Act on Financing of Future-Proof Investments.
    GermanyFinance and Banking
    POELLATH
    POELLATH
  • Article

    Once Again: Real Estate Transfer Tax Reform On The Horizon

    The German Act to Modernize the Law on Partnerships (MoPeG) will fundamentally reform the legal treatment of partnerships as of 2024. This civil law reform will also have an impact...
    GermanyReal Estate and Construction
    POELLATH
    POELLATH
  • Article

    Germany's Federal Ministry Of Finance On Cryptocurrencies And Tax: New Circular Answers Individual Questions (Part II)

    This blog post is Part II of our series on the newly published BMF circular addressing cryptocurrencies and tax.
    GermanyTechnology
    Flick Gocke Schaumburg
    Flick Gocke Schaumburg
  • Article

    Federal Ministry Of Finance Reacts To Wächtler Decision Of ECJ: No Permanent And Interest-Free Tax Deferral When Moving To Switzerland

    On 13 November 2019, the Federal Ministry of Finance issued a statement on the im-plementation of the decision of the European Court of Justice in the Wächtler case (26 February 2019 - C-581/17).
    European UnionTax
    POELLATH
    POELLATH
  • Article

    058e. The German 1997 Annual Tax Act (Item 05 of 14) - Tax Reorganisation Act

    GermanyTax
    KPMG Germany
    KPMG Germany
  • Article

    227. Old § 8b (1) KStG Requires Direct Shareholding

    GermanyTax
    KPMG Germany
    KPMG Germany
  • Article

    171. Final Version of Loss Utilisation Directive

    GermanyTax
    KPMG Germany
    KPMG Germany
  • Article

    218. Last Chance For Reorganisation Step-Up

    GermanyTax
    KPMG Germany
    KPMG Germany
  • Article

    254. Domicile and Centre of Vital Interests

    GermanyTax
    KPMG Germany
    KPMG Germany
  • Article

    BFH Updates On Business Facilities (Extended Trade Tax Deduction)

    Last fall, the Federal Fiscal Court (BFH) published three new rulings on the topic of business premises and extended trade tax deductions (BFH, July 24, 2025 – III R 23/23, DB 2025 p. 3016; BFH, September 25, 2025 – IV R 31/23, DB 2025 p. 3157; BFH, Sept. 25, 2025 – IV R 9/24). Although two rulings were in favor of the respective taxpayers, the issue of ancillary rental services in the context of the extended trade tax deduction remains a “hot topic” in trade tax assessment.
    GermanyTax
    POELLATH
    POELLATH
  • Article

    Die Zusammenarbeit mit Content Creators – ist Ihr Unternehmen steuer- und sozialversicherungsrechtlich richtig aufgestellt?

    Content Creator rücken zunehmend in den Fokus der Finanzbehörden. In Nordrhein-Westfalen hat die Steuerfahndung kürzlich eine eigene...
    GermanyTax
    Oppenhoff
    Oppenhoff
  • Article

    E-Invoicing In Germany: Validation As The New Compliance Backbone

    The German Federal Ministry of Finance (BMF) has unveiled a revised administrative guideline on mandatory electronic invoicing, dated October 15, 2025. Building on the 2024 guideline and insights from FAQs released earlier this year, this update represents a pivotal step in Germany's e-invoicing evolution.
    GermanyTax
    Alvarez & Marsal
    Alvarez & Marsal
  • Video

    German Tax Reform In 2018 – What Will Change? (Video)

    Germany is one of the main economies of Europe. In terms of fund distribution it's also one of the key jurisdictions for the Luxembourg market. On January 1st 2018, in Germany, the Tax Law will change in respect to fund taxation.
    GermanyTax
    Arendt & Medernach
    Arendt & Medernach
  • Article

    Interest On Withholding Tax Refunds In Cases Of Incorrect Application Of A Double Tax Treaty

    The Cologne Fiscal Court has ruled that taxpayers may be entitled to interest on delayed tax refunds under EU law, even when the initial refusal was based on incorrect application of a double taxation agreement rather than direct EU law provisions. This decision extends beyond previous rulings that limited interest claims to cases involving EU directives, potentially opening new avenues for taxpayers facing prolonged withholding tax refund delays.
    GermanyTax
    A&O Shearman
    A&O Shearman
  • Article

    New EU Directive On Energy Taxation Adopted By European Council For 2004

    GermanyTax
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    Positive Shift Regarding Taxation Of Management Participations

    In its decision of October 4, 2016 (IX R 43/15), the Federal Fiscal Court finally confirmed the taxation of management participations as capital gains.
    GermanyTax
    POELLATH
    POELLATH
  • Article

    Reduction Of Value Added Tax Rates – Practical Impacts

    In effect from 1 July 2020 until the end of 2020, the German legislator has decided to reduce the value added tax ("VAT") rate from 19% to 16% and from 7% to 5%; respectively.
    GermanyTax
    Mayer Brown
    Mayer Brown
  • Article

    Transfer Pricing: Significant Tightening For Financial Transactions And Services

    On 22 March 2024, the Ger­man Fe­deral Coun­cil ap­pro­ved the Me­dia­tion Com­mit­tee's com­pro­mise pro­po­sal on the Growth Op­por­tu­nities Act.
    GermanyTax
    RSM Ebner Stolz
    RSM Ebner Stolz
  • Article

    Government Support Available To German Businesses During The COVID-19 Pandemic

    The German Chancellor has confirmed that the German Federal and State Governments are willing to "do everything that is necessary and that Germany needs...
    GermanyCoronavirus (COVID-19)
    Gowling WLG
    Gowling WLG

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