05.12.2022 RETT exemption in case of upstream merger of second-tier com ... The tax exemption from real estate transfer tax (RETT) in the event of restructuring within a group under Section 6a of the RETT Act also applies to cases where a dependent second-tier company is merged with a subsidiary of a group parent company, even if in the five years after the transaction 25 percent of the shares in the parent company are transferred to a new shareholder. In his decision the Supreme Tax Court held that the subsidiary must be regarded as “controlling company” within the meaning of the RETT Act. Categories: Supreme Tax Court casesKeywords: merger, RETT exemption, controlling memb ...
13.02.2020 Tax exemption for group restructurings under Section 6a Real ... The tax exemption from real estate transfer tax (RETT) in the event of restructuring within a group under Section 6a of the Real Estate Transfer Tax Act (RETTA) does not constitute State Aid prohibited by EU law. Categories: Supreme Tax Court casesKeywords: Spin-off, real estate transfer tax, merg ...
