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Das Doppelbesteuerungsabkommen Deutschland-Schweiz (DBA D-CH) beinhaltet mit Art. 4 Abs. 3 DBA D-CH - der sogenannten überdachenden Besteuerung - eine praxisrelevante...

On 27 May 2021, the German Supreme Tax Court published two decisions dated 1 December 2021 regarding the taxation of management participations (Ref. VIII R 21/17 and VIII R 40/18).

When a corporation sells its interest in a partnership, the resulting trade tax under Section 7 sentence 2 of the German Trade Tax Act (GewStG) does not arise at the level of the selling corporation...

On June 25, 2025, Germany's Federal Ministry of Finance (BMF) published a revised draft of its administrative guidance on mandatory e-invoicing for domestic B2B transactions.

The German parliament is likely to soon pass new rules regarding interest charged on taxes for the period between when the tax is incurred and the tax is assessed.

Die Bundesregierung versprach schon im Koalitionsvertrag im Hinblick auf die Bedingungen der Mitarbeiterkapitalbeteiligung in Deutschland Besserung.

The Bundesrat has accepted the Tax Amendment Bill 2003, the least controversial of the tax bills presently in the legislative pipeline. Its entry into force for 2004 is now certain.

On June 29, 2022, the German Ministry of Finance (MoF) issued an important circular (the "2022 Circular") in the ongoing saga of the application of German Tax Act Section 49,...

According to the current view of the tax authorities, advertising expenditures for the placement of online advertising with foreign providers may be subject to a withholding tax of 15.825 % (incl. solidarity surcharge) on domestic clients.

On August 22, 2024, Germany's Federal Fiscal Court (Bundesfinanzhof) published a decision that refocuses attention on the complexities of cross-border taxation...

French société civile de placement immobilier ("SCPIs") represent an active and growing sector of the Irish real estate market.

Exit taxes will apply to private investors in investment funds who leave Germany and have purchased investment shares priced at a minimum of €500,000...

Der BFH hat in drei Parallelentscheidungen bestätigt, dass eine grundbesitzverwaltende Gesellschaft die erweiterte Kürzung des Gewerbeertrages (§ 9 Nr. 1 S. 2 GewStG)

Recently the German legislature passed a new law, exempting extraordinary profits created by the waiver of claims under restructurings from income tax liability.

It remains to be seen, which specific evidence will have to be provided in order to prove a tax-neutral repayment of contributed equity.

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.