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Avoiding real estate transfer tax in the case of intragroup restructurings

With regard to the application of the so-called ‘corporate group reservation’ clause (Konzernvorbehalt) under Section 6a of the Real Estate Transfer […]


New option model for partnerships – Part III Will exercising the option founder over special business assets?

Last time, in the second article of our series of detailed explanations of the German Act on the Modernisation of Corporation Tax Law, we discussed […]


In the case of properties, do step up models constitute a form of abusive structuring?

Frequently, in the case of property that is rented out and held as taxable assets, the tax depreciation volume has been used up, or the amount of […]


Operate photovoltaic systems and combined heat and power units free of tax charges

Many private residential properties have had small photovoltaic systems (PV systems) installed. Moreover, some people also operate small combined heat […]


Taxation of earn-out payments

In the course of M&A transactions, subsequent purchase price payments are frequently agreed. The aim of such so-called earn-out payments is either to […]


Employers may order employees to stop working from home

While for some people working from home during the pandemic was a nightmare, others certainly came to appreciate it. A case before the state labour […]


A deviating profit distribution formula is not a determinant for inheritance tax

If parents wish to transfer assets to their children, then it is frequently advisable to make a gift already during the donor’s lifetime. A parent […]


If a tenant fails to move out then the landlord can claim high loss of use compensation

If a tenant fails to move out after the tenancy has expired then they run the risk of having to pay more than the rent that they have hitherto owed.


The new administrative principles for transfer pricing – An initial appraisal of the practical impact

The German fiscal authority published new administrative principles for transfer pricing on 14.7.2021; these came into effect immediately and will […]


New option model for partnerships – Part II The effects of the notional change of legal form on special business assets

In the first article, we started our series of detailed explanations of the German Act on the Modernisation of Corporation Tax Law, which […]

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