Tax & Legal

In its judgement of 2 July 2025 ( XI R 27/22), the Supreme Tax Court ruled that a roll-over provision created incorrectly in accordance with Section 6b(3) of the Income Tax Act (ITA) must be corrected in accordance with the principles of formal balance sheet consistency.

The Supreme Tax Court has upheld the German rule providing for immediate taxation (but with a deferral option) of the transfer of a roll-over provision to be held as a fixed asset of a permanent establishment in another member state.

In this issue: PwC Reports, Official Pronouncements, Supreme Tax Court Cases, From Europe and From PwC

The Supreme Tax Court has held that a replacement reserve for assets lost through accident should be carried forward for the same four-year period as allowed by the roll-over relief provisions.