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The German Bundestag has introduced exit taxation on investments at record speed. The Bundesrat, the upper house, didn’t ratify yet but is expected to assent to the new rules so that they might enter into force starting on 1 January 2025.

The legislator has amended the transfer pricing documentation obligations, which were tightened at the end of 2022, and brought forward their application significantly. The following article explains what companies should now bear in mind.

Italy was the first country in the EU to implement mandatory e-invoicing as of January 2019 in the B2B and B2C segment. As part of our series “E-invoicing in the EU” we highlight the growing relevance of e-invoicing by examining Italy’s successful implementation and offer valuable insights for businesses that are looking to navigate this change.

The EU Commission’s ViDA initiative marks a new era in VAT compliance. In future, digitalisation will be the key step to optimising processes and meeting new requirements. Tax engines can play an important role here.

The Federal Fiscal Court (Bundesfinanzhof) had already blocked applying expanded trade tax reductions to lettings between two controlled companies belonging to the same consolidated tax group in the past. According to the Federal Fiscal Court’s latest judgment, of 11/07/2024 (III R 41/22), this is also to apply if the renting controlled company sublets the properties to third parties. This may result in additional tax burdens in the consolidated tax group in the subletting model.

Asset management GmbHs (companies with limited liability) are still the subject of discussion. Many asset managers, trading platforms and investment consultants talk this structure up as a “tax-saving model”. But what’s actually behind it? Let’s have a look at the law and how it’s implemented in practice.

In this article, you can read about the challenges that arise when preparing a purchase price allocation.

In the world of tax, compliance management systems (tax CMS) continue to be a hotly debated topic. The discussion gained new momentum from the current test phase (Section 38 of Article 97 of the Introductory Act to the Fiscal Code [EGAO]) for DAC7. Tax authorities may now promise specific simplifications for future tax audits if the current audit has confirmed the effec-tiveness of the existing tax CMS.

Last year the Federal Fiscal Court (Bundesfinanzhof – BFH) decided that paying a pension and salary to an owner-director at the same time does not mean that in principle the pension is to be classified as a hidden profit distribution. The tax authorities only partially adopted the principles of the judgment in the latest amendment of its Federal Ministry of Finance (BMF) circular. Cases where directors work part-time are critical.

The new guideline deals in detail with the allocation of wages in cases in which employees receive both taxable and tax-free wages in Germany. In particular, the application of the daily tax table for salary payment periods as of 1 January 2025 is addressed.

The EU is pushing the modernisation of the VAT system with the planned introduction of unionwide electronic invoicing (“e-invoices”). But in practical implementation, there are great differences between the EU Member States. In this article, we explain the main challenges that global businesses face and point out how you can safely navigate through the different coun-tries’ various plans for implementation.

Loans from shareholders and intragroup loan relationships (intercompany loans) are a popular means of structuring how liquidity is provided and distributed within a group of companies. If the debtor gets into difficulties, the creditor is usually affected not only by the loss of value or the bad debt but – if the loans are between corporations and the shareholding is at least 25 per cent – by the ban on tax deduction under Section 8b para. 3 sentence 4 f. of the Corporation Tax Act [KStG] as well.

In asset and succession planning, real estate is often a challenge. That’s especially the case in the current real estate crisis. As disagreeable as the situation for many property owners is, it also offers potential to structure your asset and succession planning.

In asset and succession planning, real estate is often a challenge. That’s especially the case in the current real estate crisis. As disagreeable as the situation for many property owners is, it also offers potential to structure your asset and succession planning.

In asset and succession planning, real estate is often a challenge. That’s especially the case in the current real estate crisis. As disagreeable as the situation for many property owners is, it also offers potential to structure your asset and succession planning.

In asset and succession planning, real estate is often a challenge. That’s especially the case in the current real estate crisis. As disagreeable as the situation for many property owners is, it also offers potential to structure your asset and succession planning.