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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.

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.

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.

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.

For private persons, protecting their privacy is a central need, both personally and in terms of their wealth structures. A new judgment by the German Administrative Court Cologne (Verwal-tungsgericht Köln) (17/07/2024–13 K 5996/19) protect the privacy of wealthy private individuals.

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.

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.