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- Title
Pillar Two – Globale Mindestbesteuerung vs. Hinzurechnungsbesteuerung im Transaktionsumfeld – Teil 2.
- Authors
Geiger, Florian
- Abstract
The article deals with the tax treatment of intra-group and external transactions in connection with the German regulations on controlled foreign company taxation. Various case scenarios and the effects of global minimum taxation are highlighted. It is emphasized that the overall tax burden on transactions can be significantly higher than the usual tax burden on the sale of assets subject to taxation in Germany. The text also addresses the tax treatment of asset transfers between intra-group business units and the effects of global minimum taxation on such transfers. It also explains tax aspects related to the sale of interests in foreign companies, the merger of companies, and the restructuring of companies in Germany. Finally, design options for optimizing inheritance tax burden through family foundations are considered.
- Subjects
GERMANY; FAMILY foundations; TAXATION; MERGERS &; acquisitions; ASSETS (Accounting); BUSINESS enterprises
- Publication
Die Unternehmensbesteuerung (Ubg), 2023, Vol 16, Issue 12, p687
- ISSN
1865-7222
- Publication type
Article
- DOI
10.9785/ubg-2023-161205