Inheritance Tax Act-Reform

The German legislator concluded a reform of the German Inheritance Tax Act. This Reform aims at specific relief provisions for business assets. The new version of the Inheritance Tax Act will be in force from 1 July 2016 onwards. For further details please contact us.

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Brexit – Tax implications

Britain votes to leave – The Brexit will impact cross border business between EU countries and the UK. Many German tax rules in the cross-border context include specific exceptions or benefits for business relationships within the EU or the EEA. These rules are based on the EU freedoms such as […]

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Draft circular on apportionment of profits

The German Federal Ministry of Finance published on 18 March 2016 a draft cirular on the distribution and apportionment of profits between a head office and a permanent establishment. This draft circular explains in detail (152 pages) with many examples how profits shall be allocated between e.g. a foreign head office […]

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Introduction of the Record Date-Principle in Germany

The German legislator passed an amendment of the German Stock Corporation Act (the “AktG”, “Aktienrechtsnovelle 2016”) in December 2015. The Amendment contains numerous changes and clarifications of the AktG. With respect to stock trading the amendment contains a new regulation on dividend payment date (introduction of record date for dividend payments) with effect […]

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German filing deadlines for 2015 tax returns

The filing deadline for German tax returns for the fiscal year 2015 is May 31, 2016. Only, if the taxpayer is represented by an external tax advisor, the filing deadline will be automatically extended to December 31, 2016. Notwithstanding this general extension, tax authorities may request an earlier filing of relevant tax […]

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Attribution of shares under a stock loan

The German Federal Fiscal Court (BFH) has handed down its long awaited judgment – file no. I R 88/13 – on a structured stock loan over dividend record date. According to this judgment no transfer of beneficial ownership takes place under a stock loan if the borrower receives only a […]

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