BVV compliance in 2027: Is your company ready?
The Contribution Procedure Ordinance (BVV) takes effect on 1 January 2027. Answer a few questions now to receive an assessment.
The Contribution Procedure Ordinance (BVV) takes effect on 1 January 2027. Answer a few questions now to receive an assessment.
In its judgment of 27 May 2026 (case reference 6 K 2020/22), the Cologne Fiscal Court (Finanzgericht, FG) ruled that non-resident applicants may, subject to certain conditions, have a direct entitlement under EU law to interest on delayed refunds of Germanwithholding tax. Although the case concerned an Austrian private foundation, the ruling is likely to have implications well beyond the individual case for international funds, asset managers, banks and holding companies. Leave to appeal on points of law was granted.
Since 2025, tax audit findings can have implications well beyond the tax originally audited. Section 153(4) of the German Fiscal Code (AO) requires taxpayers to apply audit findings implemented in assessments that have become final and binding to other tax returns, even where these relate to different taxes or periods not previously audited. The interaction between VAT and Insurance Premium Tax (IPT) is particularly sensitive. Under section 4 no. 10 of the German VAT Act (UStG), a single set of facts can affect both tax regimes. This article explains the new compliance obligations, highlights areas of uncertainty in interpreting the rules and outlines how businesses can manage the associated risks systematically.
In its judgment of 20 May 2026 (case reference IV R 37/23; parallel judgment IV R 4/26), the German Federal Fiscal Court (BFH) held that a market support payment paid to a foreign related party may be business-related and consistent with the arm’s length principle where the payment serves to safeguard or increase the payer’s own royalty income. The ruling provides additional arguments in support of existing distribution and limited-risk distributor (LRD) structures.
Where a limited liability company [GmbH] pays a person close to its shareholder an excessive purchase price for a property, real estate transfer tax is assessed on the full purchase price (section 8(1) of the Real Estate Transfer Tax Act [Grunderwerbsteuergesetz–GrEStG]) – even if the excess price, as a hidden profit distribution [verdeckte Gewinnausschüttung–vGA], simultaneously triggers gift tax. An amendment of the real estate transfer tax assessment on account of conflicting tax assessments under section 174(1) sentence 1 of the Fiscal Code [Abgabenordnung–AO] is ruled out, because the relationship of mutual exclusivity between the two taxes covers only gifts of real property within the meaning of section 3 no. 2 sentence 1 of the Real Estate Transfer Tax Act. The decision confirms that section 174 of the Fiscal Code is not a general instrument for overriding the finality of assessments (Federal Fiscal Court [Bundesfinanzhof–BFH] judgement of 29 Jul 2026, file ref. II R 11/24).
11 Mar 2026
The audit and advisory firm Grant Thornton in Germany ended the 2024/25 financial year on September 30, 2025, with consolidated revenue of EUR 264 million (up 6 percent on the previous year). The Audit & Assurance division recorded particularly strong growth with an increase of 14 per cent compared to the previous year.
09 Feb 2026
Martin Biegel joined the Senior Leadership Team of the audit and advisory firm Grant Thornton Germany in February as the new Chief Financial Officer/Chief Operating Officer (CFO/COO) and in this role will actively help drive the firm’s strategic development.
13 Oct 2025
The Equity Partners of Grant Thornton AG Wirtschaftsprüfungsgesellschaft (“Grant Thornton Germany”) have approved the strategic partnership with international private equity firm Cinven. This marks a key milestone for the transaction initially announced on 10 September 2025, which is expected to close in the first quarter of 2026. The partnership further strengthens Grant Thornton Germany’s position as a leading, trusted service provider in the German audit and advisory market, ushering in its next phase of growth.