What do the expected future German government’s plans look like for private equity clients, family offices and family businesses? In this briefing, we analyse the coalition agreement to see what tax changes private clients can expect in the new parliament and why it’s crucial to consider business and personal succession now.

In a landmark judgment dated 3 December 2024, the German Federal Fiscal Court (Bundesfinanzhof) opened the door for German-resident beneficiaries of third-country family trusts, family foundations, and similar structures to potentially be exempt from German CFC (Controlled Foreign Corporation) taxation.

Moving abroad may have tax consequences that are often underestimated. When moving to a tax haven or low-tax country, “extended non-resident tax liability” for income tax as well as inheritance and gift tax often goes unrecognised. This is why particular attention should be paid to a recent decision by the German Federal Fiscal Court (BFH). In this article, we shed light on what those moving abroad need to know about the German extended limited tax liability.