Tax-neutral restructuring – formalities to be observed in filing applications
Corporate tax advisory in practiceWhen 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.
