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The European Court of Justice (ECJ) thwarts the plans laid down in the German government’s coalition agreement to strengthen German corporate code termination. The Societas Europaea (SE) remains attractive, particularly to the mid-market.

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.

Legislation and case law have massively increased the importance of having a proper and effective HR compliance management system (HR CMS). If the rules are not complied with, directors, board members and the supervisory board can be directly liable. This liability risk can be avoided by using the right instruments to prevent such infractions. An HR compliance management system (CMS) can help here. We’ll design a customised HR CMS for you and give you assistance with implementing it, or we can audit your existing HR CMS. You’ll gain assurance, be able to identify risks and comply with your statutory duties.

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.

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.

On 5 June 2024 the German government published the draft bill for an Annual Tax Act for 2024. Amongst other areas of German income taxation, the bill especially includes changes and new regulations that affect the area of tax restructuring, which can be seen, at least in part, as a response by the legislature to recent judgments by the German Federal Constitu-tional Court and Federal Fiscal Court. In this article, we take a look at the proposed changes and their potential effects.

Federal Ministry of Finance allows nationals of EU or EEA member states with residence or habitual abode in Switzerland to apply for voluntary income tax filing in Germany.