Chapters in this book

1. Frontmatter i
2. Authors v
3. Foreword vii
4. Content ix
5. Glossary xiii
6. I. Tax
7. 1. Taxation of Inbound and Outbound Investments
8. Tax Classification of Foreign Legal Entities (‘Comparability Test’) 1
9. The Taxation of German Corporations and Partnerships by Comparison 11
10. International and Domestic Aspects of German Group Taxation 25
11. Controlled Foreign Company Legislation 41
12. Repatriation by Foreign Investors of Profits from German Investments 53
13. Cross-Border Investments in German Private Equity Funds 67
14. Typical Transaction Structures for Buyout Investments in Germany 81
15. Taxation of Partnership Income Under German International Law 93
16. German Income Taxation of Foreign Partners in German Trading Partnership 103
17. German Tax Aspects in M&A Transactions 113
18. Taxation of Real Estate Investments in Germany 125
19. Tax Aspects of Corporate Financing 139
20. The German Investment Tax Act 155
21. 2. Transfer Pricing
22. Taxation of Royalties Between Affiliated Companies 165
23. German Transfer Pricing Documentation Requirements 177
24. Business Restructurings 187
25. 3. Reorganization Tax
26. An Overview of Reorganizations Under German Tax Law 199
27. Tax-Neutral Contributions in Kind of Business Units 215
28. Share-for-Share Transactions 225
29. Foreign Reorganizations with a Connection to the German Tax Net 235
30. 4. Tax Accounting
31. Provisions in German Income Tax Law 245
32. Specific Features of Tax Accounting in Germany 257
33. 5. VAT, Trade and Real Estate Transfer Tax
34. Subordination or Close Links 267
35. International Aspects of German Trade Tax 281
36. The Cornerstones and Quirks of Real Estate Transfer Tax 293
37. 6. Tax Procedure
38. Tax Disputes and Litigation in Germany 309
39. Tax Audits in Germany 321
40. Ruling Practice in Germany – Achieving Legal Certainty on Taxation 331
41. II. Private Clients and Succession Planning
42. Unlimited and Limited Inheritance Tax Liability of Individuals and Business Entities 343
43. Foundation and Trust in Succession Planning 353
44. Inheritance and Gift Tax Planning Strategies for Individuals Subject to Nonresident Taxation (Foreigners) 367
45. Immigration and Emigration of Individuals 379
46. Using German Tax Incentives for Nonprofit Organizations Across National Borders 393
47. Taxation of Sportsmen and Artists 403
48. III. Corporate, M&A and Labor/Employment Law
49. Legal Forms in German Corporate Law 415
50. Private M&A in Germany 429
51. M&A Involving Listed Corporations 443
52. Cross-Border Reorganizations 453
53. Corporate Reorganizations in Germany 467
54. Legal Aspects of Investments in German Real Estate 481
55. Delisting as a Component of Taking Private Transactions 493
56. German Corporate Governance Code 501
57. Recent Developments in Corporate and Financial Restructuring 513
58. Corporate Litigation in Germany 523
59. Forms of Distribution Under German Commercial Law 539
60. Matrix Structures as a Means of Steering Groups Under Corporate Law and Labor-and-Employment Law 553
61. Corporate Codetermination and Its Avoidance 565
62. IV. Tax Crime
63. Voluntary Disclosure of Tax Evasion Under German Law 579
64. Changed Criminal Tax Law Framework 591
65. V. Public Auditing, Accounting and Business Valuation
66. A Comparison of Valuation Principles in Germany and Internationally 603
67. Financial Statements: Disclosure Requirements and Ways of Avoiding Them 615
68. Accounting for Advertising Spots 631
69. Tax Compliance – A Challenge for Tax Departments 641
70. Index 655