KPMG report: German case law regarding transfers of functions

Some courts have held in favor of taxpayers arguing their transactions did not result in transfers of functions.

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January 28, 2025

The tax treatment of transactions involving a transfer of functions (ToF) is explicitly regulated under German law, and when a ToF is found to occur, taxpayers generally face a significant tax assessment. However, some courts have held in favor of taxpayers arguing that their transactions did not result in ToFs.

Read a January 2025 report prepared by the KPMG member firm in Germany

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