While the announced reform of the Real Estate Transfer Tax Act continues to be a long time coming, there has been a fundamental realignment with regard to internal group restructurings. Several rulings of the Federal Fiscal Court as well as a recent application decree of the tax authorities largely put an end to the discussions on the interpretation of sec. 6a GrEStG. As a result of the legal and planning certainty that has now been achieved, the exemption provision will become considerably more important in practice.

Since 1 July 2020, special reporting obligations apply in Germany for so-called cross-border tax arrangements. These result from the implementation of the European Directive “DAC 6”. Cross-border tax arrangements must be reported to the Federal Central Tax Office within 30 days, otherwise fines may be imposed. The tax administrations of the EU Member States will exchange the disclosed information among themselves through an automated procedure.

The so-called Platform to Business Regulation (in short “P2B-Regulation”) establishes rules for the first time to achieve a certain balance in view of the steadily increasing power of platform operators on the Internet (“Platform Operators”). For some situations and problems that have proved to be particularly critical for companies in the past, the regulation attempts to encourage Platform Operators to be fairer. The future will show how effective this Regulation will actually be.