9/9/2025 10:29:43 AM German Federal Fiscal Court rules against double RETT on share deals By Sebastian Adam Sebastian Fernkorn In a decision dated 9 July 2025, the German Federal Fiscal Court (docket no. II B 13/25) addressed the issue of a double assessment of...
6/10/2025 10:27:55 AM Re-domiciliations and cross-border mergers: key tax questions By Victor Camatta Tanja Velling Re-domiciliations and cross-border mergers can be great options for a restructuring and, within the EU, the rules governing both types of...
8/2/2023 10:59:50 AM Criminalisation of tax issues in Europe By Stefano Brunello Dormal Yves Rutschmann Jan Adami Teresa Morales +1 more... Show less In recent years, there has been a steep increase in criminal proceedings for tax matters in some European countries, such as France,...
7/31/2023 9:41:48 AM Purpose tests in anti-abuse or anti-avoidance provisions: perspectives across Europe By Stefano Brunello Dormal Victor Camatta Mees Vergouwen Jan Adami Tanja Velling Marta Pontes Teresa Morales +4 more... Show less In order to carry out a transaction, taxpayers are generally free to choose between different structures and tax regimes, and to choose...
7/31/2023 9:39:33 AM Purpose tests in anti-abuse or anti-avoidance provisions in Germany By Jan Adami Germany has a general anti-abuse rule (GAAR) as well as other purpose tests under various specific anti-abuse rules (SAARs) in different...
7/26/2023 8:51:51 AM Beneficial ownership: perspectives across Europe By Stefano Brunello Dormal Pierre-Henri Durand Mees Vergouwen Jan Adami Tanja Velling Marta Pontes Teresa Morales +4 more... Show less Across a number of European jurisdictions, relief from withholding tax may be denied where the recipient of a dividend, interest or...
7/26/2023 8:47:21 AM Beneficial ownership from a German perspective By Jan Adami In practice, the beneficial ownership test is most often applied in connection with dividend withholding taxes but may also be relevant...
7/14/2023 11:01:18 AM Another RETT reform in Germany? By Sebastian Adam A far-reaching reform of the German real estate transfer tax (RETT) rules has been proposed which, if implemented, is intended to apply...
6/19/2023 9:47:19 AM German tax administration gets the attention of US Congress for register cases By Sebastian Heinrichs The German register cases have been the subject of discussions in the public and also in this blog for almost three years, from the start...
1/26/2023 11:07:56 AM Share deals in peril of double taxation under new RETT law By Gunther Wagner The German tax authorities have adopted the controversial "signing closing theory" for share deals involving at least 90% of the shares...
11/16/2022 12:20:45 PM German Tax Authorities publish long awaited guidance on new RETT law By Sebastian Adam Gunther Wagner The 2021 reform of the German Real Estate Transfer Tax Act (Grunderwerbsteuergesetz or GrEStG) included, among other things, three...
6/24/2022 3:01:56 PM German foreign-to-foreign IP taxation: Ministry listens to complaints and prepares for an end By Sebastian Heinrichs On 16 June 2022, the German Federal Ministry of Finance (MoF) submitted to the finance committee of the German parliament its evaluation...
3/21/2022 3:50:08 PM Cum/ex, the final decision: And in the end, short sales didn’t even matter By Sebastian Heinrichs The German Federal Fiscal Court (Bundesfinanzhof, BFH) published its long-awaited ruling on the legality of so-called "cum ex"-structures...
1/20/2022 4:34:07 PM A question of substance – a first look at the EU Commission's "Unshell Proposal" By Isabella Zimmerl Two recent trends in international taxation – an increase in taxpayers' obligations to document and share information with tax...
9/22/2021 3:50:25 PM German tax laws pushed through before end of current parliamentary term By Verena Klosterkemper The German legislature has enacted a large number of new and amending provisions with remarkable speed, just before the current...
9/2/2021 9:41:43 AM German Ministry of Finance publishes guidance on transitional provision of new RETT law By Sebastian Adam The German Ministry of Finance has published guidance on the transitional provision with respect to the revised German Real Estate...