10.11.2017 Tax Consolidation Groups (“Organschaft”) for income tax purp ... According to a decision of the Supreme Tax Court published on 9 November 2017 a profit pooling agreement will not be recognised for tax purposes where the compensation agreement with the external shareholder contains both the right to a variable compensation payment calculated on the basis of the profits of the subsidiary/controlled company/"Organgesellschaft" (“subsidiary”) and a fixed amount. Categories: Supreme Tax Court casesKeywords: Organschaft, Corporation tax, compensati ...
