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Impairment valuation is a frequent point of contention in tax audits. This also applies to write-downs of work in progress, which allow expected future contract losses to be partially recognised on the balance sheet date. In recent years, external factors like disruption to production during the COVID pandemic, increases in material and energy costs and geopolitical disruption to supply chains led to considerable strain in long-term production.

When businesses want to be successful in the long-term, they have to adjust quickly to changing conditions. Under certain circumstances, the German Transformation Tax Act (Umwandlungssteuergesetz) allows businesses to be reorganised without any adverse effect on income tax. Important for tax neutrality is particularly carrying over tax book values, for which an application has to be made. The Federal Fiscal Court (Bundesfinanzhof) regularly has to decide on disputes involving applying to carry over tax book values, which shows just how relevant this subject is. Also in view of the fact that the formal conditions are now being more stringently checked in tax audits, taxpayers should be very careful and diligently when making the filing application.

Preservation of Tax Loss Carryforwards in Corporate Restructurings: German Tax Authorities Clarify the Restructuring Exception

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.

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.

How does EaaS work and how can machinery and plant manufacturers take advantage of this model? What legal, tax and ESG aspects need to be considered? We answer the most crucial questions.