24.02.2025 RETT: No tax relief for foreign intra-group share transfer The Supreme Tax Court decided that the contribution of all shares in an indirectly property-owning company by a corporation under Irish law to the plaintiff against consideration is subject to real estate transfer tax pursuant to Section 1 (3) Real Estate Transfer Tax Act. The exemption on intra-group restructures (conversions) under Section 6a Real Estate Transfer Tax Act was not available. Categories: Supreme Tax Court casesKeywords: share transfer, unification of shares, r ...
17.11.2024 Application for transfer at book value to be made also in a ... In a most recent judgment, the Supreme Tax Court held that the application for maintaining the book values in accordance with Section 3 (2) sentence 1 of the German Reorganization Tax Act can be made in the notarial deed on the reorganization of which the notary sends a certified copy to the responsible tax office in accordance with § 54 para. 1 of the Income Tax Implementation Ordinance. Categories: Supreme Tax Court casesKeywords: Tax Book Values, restructuring, transfer ...
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 ...
