In the case of a pension commitment financed by deferred compensation, the tax office may not impose strict requirements for tax recognition.

If, in contrast to the shares of the other shareholders, the profit share of a majority shareholder is not distributed but allocated to the revenue reserve, there is no inflow of investment income.

Even without a major annual tax law last year, there were again some changes in tax law at the turn of the year.

Large donations to a foundation established by the shareholders can be a hidden profit distribution.

In order for the tax office to assume a hidden profit distribution due to an excessive interest-bearing shareholder loan, it must take all interest-relevant factors into account appropriately.

Since August 1, 2021, many companies and associations are required to register in the Transparency Register.

Losses from a loan to a corporation are to be recognized for tax purposes if it is certain that the corporation will no longer make payments.

In addition to a corporate income tax option for partnerships, the corporate income tax framework for corporate groups and international companies will be improved.

The fact that dividend income is only disregarded for corporate income tax purposes if the shareholding is at least 10 % is not constitutionally objectionable.

If the annual financial statements are adopted late, the tax office may not assume a fictitious inflow of bonuses already at the time when the annual financial statements should have been prepared.