26. September 2022 Attribution of taxable income in fiduciary cases The Supreme Tax Court decided in the specific case of a Contractual Trust Arrangement that a fiduciary relationship within the meaning of Section 39 (2) No. 1 Sentence 2 of the German Fiscal Code which is recognized for tax purposes may still exist after insolvency proceedings were initiated over the assets of the trustor. Kategorien: Supreme Tax Court casesSchlagwörter: trust, fiduciary