BINDING EFFECT OF CONSULTATION AGREEMENTS – FURTHER DEVELOPMENT OF INTERNATIONAL TAX LAW BY German Federal Tax Court (BFH)

The German Federal Tax Court (BFH) has in a recently published ruling dated 30.09.2020 – I R 37/17 further developed its case law in relation to the the binding effect of so-called consultation agreements between two jurisdictions. In the case at hand, the parties disputed the number of non-return days within the meaning of the … Continued

German real estate tax exemption for group reorganizations pursuant to sec. 6a RETTA is not considered as unlawful state aid by Court of Justice of the European Union.

Decision of CJEU as of 19 December 2018 (C-374/17) safeguards executed and planned group reoarganizations pursuant to which the RETT exemption in accordance with sec. 6a RETTA was or shall be applied. On this Basis sec. 6a RETTA shall generally be applicable for past and future reorganisations. Our complete statement on this decision is printed … Continued