englischThe tax effectiveness of profit distribution agreements in partnerships is of high academic interest and practical relevance. This publication examines the largely unresolved question of whether special allocations of individual tax items is possible under German tax law.

In particular, [...]

englischThe success of restructurings regularly depends decisively on the tax treatment of profits triggered by reorganization measures. However, the application of the tax exemption of Section 3a EStG, which was created for this purpose, is fraught with conflict due to numerous questions of [...]

englischIt was only in June 2021 that the last remaining pieces of the ATAD were transposed into German tax law (German ATAD Implementation Act – “ATADUmsG”). An essential part of the German ATAD Implementation Act is the amendment of the national CFC rules. The reform of the national CFC rules [...]

englischAs a hybrid company form between a corporation and a partnership, the partnership limited by shares moves between non-transparent and transparent taxation. It has a special position in the domestic dualism of corporate taxation. This impacts the international tax law as well. The study [...]

englischThe work is dedicated to the two fundamental elements of the non-transparent taxation regime in the German Investment Tax Act – Advance Lump Sum Amount and Partial Exemption Regime. In order to approach these, the author first introduces the basics of the legal subject, considering both the [...]

englischThe taxation of carried interest still raises questions today. Even 20 years after the introduction of a statutory regulation, it is unclear whether carried interest represents a remuneration for the contributions made by the managers for the benefit of the fund's investors or whether it is [...]

englischThe study is dedicated to the treatment of pension provisions in the course of a harmonised European balance sheet tax law. Despite concrete reform ideas on the harmonisation of balance sheet tax law, such as the CCCTB proposal, the tax treatment of pension provisions is not only treated as [...]

englischThis dissertation deals with the so-called license barrier (§ 4j EStG), which the author classifies as a measure to combat undesirable tax arrangements and harmful tax competition. On the basis of an analysis of the BVerfG and EuGH case law, the author elaborates the constitutional and union [...]

englischAgainst the background of recent BFH case law, this dissertation opens up new perspectives on a "classic" of insolvency tax law, the treatment of VAT in insolvency proceedings. The author argues that the difficulties of interlocking VAT law with insolvency law are due to the way in which the [...]

englischThe work deals comprehensively with the significance of the OECD model commentary for the interpretation of double taxation agreements and processes literature as well as case law beginning with the work of the League of Nations through the first OECD model commentary from 1963 until today. [...]