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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.

In a Circular on 28 June 2024 the Federal Ministry of Finance announced that from 2025 there will be a Germany-wide requirement to report on electronic cash registers. This rule had been suspended until now because of a lack of technical implementation on the level of German Tax Offices. Now that this function has been added to the German online tax return portal www.elster.de, the conditions have now been met for the businesses concerned to fulfil this reporting requirement.

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.

On 11 March 2025 the Council reached an agreement on the exchange of information for GloBE Information Returns (GIR) for companies affected by Pillar Two. This is designed to create a Union-wide basis for the automatic exchange of information on GloBE Information Returns. For companies with Pillar Two duties, this means that in future they will be able to file their GIR centrally in only one member state. DAC9 thereby provides a substantial simplifica-tion for multinational and large German groups of companies that fall under the German Mini-mum Tax Act (MinStG).

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.

In their 2025 coalition agreement, the CDU, CSU and SPD have reached agreement on a wide range of tax and economic measures. Key elements include investment incentives, tax relief and stimuli to digitise public administration and business. The planned changes affect both companies and private taxpayers. In this article, we summarise the most important points.

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.

The federal election 2025 took place on 23 February and marked a decisive turning point in Germany’s political and economic future.

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.

We present you the recent case law of the Federal Fiscal Court and a regional Fiscal Court on the tax implications of pension obligations.

Tax compliance is more than just a legal obligation – it protects a company and its management from unexpected risks and fines, or even reputational damage. Innovative tools and queries as part of a thoroughly designed TCF can help companies stay on the safe side in the future. In many situations, risks such as bogus self-employment and incentives can be quickly and accurately identified using innovative tools and queries and directly allocated to risk categories to minimize – if not fully mitigate, negative outcomes.

Exit taxation, often also called exit tax (Wegzugsbesteuerung or Wegzugsteuer), is a central topic in German tax law and is becoming increasingly important in the context of international mobility.

After a tense election, the new coalition seems to be certain – the next German government will probably be formed by the CDU/CSU and the SPD. But what does this mean in terms of tax for family businesses, family offices and (Ultra)-High-net-worth individuals? Based on the parties’ manifestos, we’ve analysed what tax changes private clients can expect in the new legislative period and why it’s crucial to consider business and wealth succession now.