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  • Article

    Update On A German Tax Problem: Double Assessment Of Real Estate Transfer Tax For The Acquisition Of Company Shares

    The German Federal Finance Court (BFH) has issued a landmark interim decision with far-reaching implications for international mergers and acquisitions (M&A) practice.
    GermanyTax
    GGI | Global Alliance
    GGI | Global Alliance
  • Article

    Economic Ownership And Securities Lending & WHT On Crypto Fund Units

    On 29 September 2021, the German Federal Fiscal Court ("BFH") gave a ruling on the tax legal concept of economic ownership in the context of securities lending.
    GermanyTechnology
    WTS Global
    WTS Global
Article

225. Interest-Free Loans Not Abuse Of Law

GermanyTax
KPMG Germany
KPMG Germany
  • Article

    Branch Capital for Banks - Finance Ministry Republishes Draft Decree

    The finance ministry has published a slightly amended version of its draft decree of February 2004 on the minimum branch capital to be attributed to branches of foreign banks for tax purposes.
    GermanyTax
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    German Federal Fiscal Court Deciding On Unjustified Discrimination Of Non-EU Pension Funds

    Under the German Corporate Income Tax Act (Sec. 32 para. 1 no. 2 German Corporate Income Tax Act, KStG), in the case of dividend payments, non-EU pension funds...
    GermanyTax
    Morrison Foerster
    Morrison Foerster
  • Article

    Tax Law And The Metaverse - What Tax Challenges Do Companies Face In The Virtual World?

    Impressive innovations are anticipated in the metaverse and are thus causing an extraordinary stir in a multitude of areas of life. In the meantime, hardly any other field...
    GermanyTax
    Oppenhoff
    Oppenhoff
  • Article

    Changes To Intrastat Reporting

    The International Trade in Goods Statistics (ITGS) is based on two data compilation systems: one for extra-EU trade statistics (data relating to trade of goods with non-member countries) and...
    GermanyInternational Law
    WTS Global
    WTS Global
  • Article

    172. Stepped-Up Basis for Trade Tax Purposes on Reorganisation of a Corporation as a Partnership

    GermanyTax
    KPMG Germany
    KPMG Germany
  • Article

    202. High Court Upholds Dividend Stripping Schemes

    GermanyTax
    KPMG Germany
    KPMG Germany
  • Article

    Bavarian Tax Authorities Comment On Tax Treatment Of Employee ‘Hurdle Shares’

    The Bavarian State Tax Office has issued groundbreaking guidance on hurdle shares, a specialized employee participation instrument featuring negative liquidation preferences. This ruling addresses critical questions about when and how these shares trigger taxable income, distinguishing between the initial issuance and subsequent disposal of shares. The decree provides clarity on whether proceeds constitute employment income or capital gains, potentially reshaping Germany's startup compensation landscape.
    GermanyTax
    Greenberg Traurig
    Greenberg Traurig
  • Article

    Circular On 2012 Anti-Treaty / Anti-Directive Shopping Rule Issued

    On January 25, 2012, the German Federal Ministry of Finance has published a circular regarding the withholding tax relief of foreign companies.
    GermanyTax
    POELLATH
    POELLATH
  • Article

    German Registered IP: New Taxation Of Transactions Between Non-German Parties

    In a decree published November 6, 2020, the German tax authorities confirmed their view that transactions between non-German parties (e.g., between two U.S. companies)...
    GermanyTax
    Morrison Foerster
    Morrison Foerster
  • Article

    Germany Improves Tax Benefits For Employee Share Plans

    Effective 1st January, 2024, the German legislator has further improved the tax environment for employee share plans as part of the Future Financing Act ("Zukunftsfinanzierungsgesetz").
    GermanyTax
    Alvarez & Marsal
    Alvarez & Marsal
  • Article

    Moving Into And Out Of Germany – When The Fiscal Authorities Reach Their Limits

    For many coming from other countries, Germany is an attractive country to which to move. At the same time, each year thousands of people leave Germany for a limited period of time or permanently.
    GermanyTax
    POELLATH
    POELLATH
  • Article

    Pillar Two (WTS Global ICT Newsletter)

    On 20 December 2021, the OECD published the model rules on global minimum taxation ("Pillar Two"), on which around 140 countries have agreed as part of the work of the OECD's Inclusive Framework.
    GermanyTax
    WTS Global
    WTS Global
  • Article

    Update On The Luxembourg Government's 2017 Tax Reform Plans

    Earlier this year, the Luxembourg government announced proposed changes to the country's corporate and personal tax frameworks, including a progressive reduction (in two steps) of the corporate income tax (CIT) rate from 21% to 18%.
    GermanyTax
    TMF Group BV
    TMF Group BV
  • Article

    New Tax Law Developments For Pension Commitments

    During the past months, the German Federal Tax Court (Bundesfinanzhof ; BFH) had several occasions to comment on individual issues connected with the accounting of provisions in the context of asset transactions between companies.
    GermanyEmployment and HR
    Jones Day
    Jones Day
  • Article

    Share Deals: Geplante Änderungen im Hinblick auf die Grunderwerbsteuer

    Das Bundesministerium für Finanzen (BMF) hat einen Diskussionsentwurf für ein Gesetz zur Novellierung des Grunderwerbsteuergesetzes erarbeitet.
    GermanyReal Estate and Construction
    Morrison Foerster
    Morrison Foerster
  • Article

    Draft Of Future Financing Act Published – Tax-Free Share Schemes To Come?

    The Draft Act shall introduce a number of changes to the law of financial markets, corporate law, and tax law. The purpose of these changes is the strengthening of the German capital market...
    GermanyTax
    Morrison Foerster
    Morrison Foerster
  • Article

    Spin-Offs Hindered Without Cause: New Decree Endangers Tax Neutrality

    In the opinion of many M&A experts, transaction activities in 2012 should be stimulated by spin-offs and carve-outs.
    GermanyTax
    Oppenhoff
    Oppenhoff
  • Showing 201–220 of 521 results

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