Tax-related questions of a group often focus on other aspects than those covered by the ordinary tax law.

Loss set-off strategies, finance optimizing (in both domestic and international context), finding tax-preferential holding locations, difficulties in defining and checking transfer prices in deliveries and services across the boarder, limitations by the German external tax law and the opportunities arising from a dense network of German double taxation agreements constitute the array of possible deliberations.

It is necessary to identify whether there exist appropriate conditions for a trade and turnover tax group as well as to assess a possible creation of a corporate income tax group through a profit and loss transfer agreement.

Due to the omission of the tax credit system and other substantial changes in the tax law, the new business tax law effective as of January 2001 will bring about completely new questions not only on a domestic level but through its retroactive effect on the double taxation law also on the international one.


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