11.02.2021 Issue of shares as part of corporate action (spin-off) The Lower Tax Court of Lower Saxony ruled that the allocation of shares in the course of a restructuring of Hewlett-Packard Company meets the requirements of a spin-off within the meaning of Sec. 20 (4a) Sentence 7 of the German Income Tax Act. Thus, there is no taxable distribution in kind at the time of the share allotment. Categories: Tax CourtKeywords: Spin-off, distribution-in-kind, corporat ...