DAC6 Reporting - Timeline At its meeting on 8 May, the European Commission decided to submit a proposal to the Council to defer the first reporting dates. After a political agreement was reached on 3 June, an amending directive was adopted and came into force on 27 June. Both the European … [Read more...]
The New German Inheritance and Gift Tax Act
The New German Inheritance and Gift Tax Act – finally meeting the constitutional principles? According to the new Inheritance and Gift Tax Act (IGTA), a multitude of (systematic) changes results for the determination of non-privileged assets, above all due to the consideration of debts, a … [Read more...]
Corporate income tax group
The Federal Tax Court in Munich (BFH) decided two cases, that concern the corporate group taxation rules in Germany (sec. 14 Corporate Income Tax Act). Precondition to form a tax group One of the preconditions to form a German tax group is the controlling influence of a company over another … [Read more...]
Addback on dividends
5 % Addback applies on CFC income The Federal Tax Court (BFH) decided, that the lump-sum addback of 5 % of dividends received applies, even if the income has been already taxed due to the German CFC rules. In the particular case, the resident taxpayer payed taxes on the income allocated from … [Read more...]