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Planned modernisation of external tax audits

A draft law published by the Federal Ministry of Finance (Bundesministerium der Finanzen, BMF) includes proposed changes related to external tax […]

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European tax law – When does a business owner have a fixed establishment?

A matter that is often disputed with fiscal authorities is the question of the circumstances under which a German parent company would create another […]

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Measures to provide relief for employees in France

In France, the lawmakers have likewise adopted a number of legal provisions in order to compensate for inflation and higher energy prices. These […]

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New possible ways of avoiding insolvency proceedings

The German Federal government approved the Stabilisation and Restructuring Framework legislation (Gesetz über den Stabilisierungs- und […]

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Minority shareholding managing directors – Social insurance payment obligation despite special rights

In recent years, case law related to the assessment of a managing director under social security law has steadily developed further. The Federal […]

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Customs app for complying with import rules

The Federal Ministry of Finance has released a customs and postal app (Zoll-und-Post-App) as well as a customs and travel app (Zoll-und-Reise-App). […]

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The tax treatment of reorganisation-induced additional transfers in the case of a consolidated tax group

It is the view of the fiscal administration that a merger within an existing consolidated tax group structure at fair market values under German […]

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Cross border group financing – An update on the arm’s length nature

The Federal Fiscal Court’s (Bundesfinanzhof, BFH) ruling on interest rates for shareholder loans has been a subject covered in our previous articles […]

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The ‘royalty barrier’ rule – BMF sets out the requirements for preferential regimes

Since the introduction of the ‘royalty barrier’ rule (Section 4j of the German Income Tax Act), limits have been placed on the tax deductibility of […]

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The size effect in business valuation – The causes and risks of higher-than-average returns from small companies

In the context of business valuation, it is always noticeable that, when compared with large companies, small companies generate higher-than-average […]

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