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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 […]

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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 […]

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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 […]

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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 […]

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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 […]

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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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Constructive dividends in the context of intra-group allocations

When assessing whether or not an amount should be categorised as a constructive dividend, the question that always arises relates to the arm’s length […]

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Crediting foreign withholding tax against German trade tax

According to previous regulations, it was possible to credit foreign withholding tax only against German income tax and corporation tax, but not […]

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Gifting and bequeathing – Securing tax advantages through planning

Transferring assets to the next generation early on makes it possible to achieve big tax advantages while still providing for the future of the donor. […]

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Kindergarten fees: Tax-free employer subsidies reduce the special expenses deduction

Many employers subsidise the accommodation and care of their employees’ children, who are not obliged to attend school, in kindergartens and similar […]

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