The BFG (03.08.2023, RV/5101166/2018) has commented on the fulfilment of the criteria for a shell company acquisition. In this case, changes in the economic structure and the shareholder structure were denied. The criteria for a shell company acquisition were therefore not met, which is why the taxable Limited Liability Company (“GmbH”) was able to claim the existing losses for tax purposes.
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BLOG.TAX
Federal Fiscal Court Decision on Tax Loss Forfeiture due to Acquisition of a Shell Company
Blog.Tax
Federal Fiscal Court: New court decision on violations of the limitation of deductions of manager salaries
The BFG („Bundesfinanzgericht“) has commented on questions relating to violations of the limitation of deductions pursuant to § 20 para. 1 no. 7 Income Tax Act (“EStG”) on "manager salaries" and established criteria for culpability in the event of non-compliance with this limitation.