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Exchange Rate Losses from Shareholder Loans Granted by Substantial Shareholders Are Not Tax-Deductible

In its decision dated April 24, 2024 (I R 41/20), the Federal Fiscal Court (BFH) decided for the legal status up to December 31, 2021 that exchange rate losses from loans granted by a substantial shareholder (>25 %) are not...more

10/9/2024  /  Loans , Shareholders , Tax Deductions

Lack of Regulation on Book Value Transfer Between Partnerships with Identical Shareholdings Unconstitutional

In its decision dated 28 November 2023 (2 BvL 8/13), the German Federal Constitutional Court (BVerfG) ruled that Sec. 6 Para. 5 Sent. 3 German Income Tax Act (Einkommensteuergesetz, EStG) violates the principle of equality...more

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