Go Beyond

In its judgment of 27/11/2024 (case I R 23/21), the Federal Fiscal Court (Bundesfinanzhof – BFH) held that holding partnerships engaged purely with management may act as the controlling company within a consolidated corporation tax group, even if they do not provide any intra-group services for compensation. This decision constitutes a significant expansion of the understanding of commercial activity as defined by the Corporation Tax Act (KStG) (sections 14(1) no. 2 sentence 2) and the Income Tax Act (EStG) (section 15(1) sentence 1 no. 2).

Transfer prices are increasingly a focus for national and international tax authorities. The regulatory requirements are developing dynamically, while tax audits are becoming ever more thorough and complex. Companies’ resources are under more and more pressure. They are facing the need to align their transfer pricing systems strategically and prioritise topics. An individually developed transfer pricing strategy is essential to minimise risks and avoid tax disputes. At the same time, opportunities are presenting themselves – more transparency in intercompany relations, the use of structured data and digitally supported processes.

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.

Operators of digital platforms must submit their report of traders on their platform to the Federal Central Tax Office (BZSt) by 31 January 2025. Find out what you need to do in this article.