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, [...]
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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 [...]
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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 [...]
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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 [...]
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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 [...]
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