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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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Registration requirements in the LUCID Packaging Register for producers and retailers

The amended version of the Packaging Act (Verpackungsgesetz) came into effect on 3.7.2021. In the following section we outline the amendments as well […]

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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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Trade tax exemption – A question of proportionality

Companies that exclusively manage their own real estate are able to file an application to make a reduction to their trading profits so that, […]

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Developed real estate – New guideline on the apportionment of the purchase price

When purchasing a rental property, it is generally advantageous for landlords if the local tax office allocates as high a share of the purchase price […]

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New option model for partnerships – Part I: System change upon exercising this option

The Act on the Modernisation of Corporation Tax Law (Gesetz zur Modernisierung der Körperschaftsteuer, KöMoG) is likely to become applicable as of […]

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