On 1 February 2022, the new circular no. 5a on tax-neutral restructurings was published.The following key adjustments were made in the circular:
The consequences for the capital contribution reserves for the individual restructuring situations were explained.
- A participation rate of 10% is required for tax-neutral spin-offs and replacements (instead of 20%).
- Holding split
- Partially tax-neutral restructuring
- The levying of the issue duty in the event of a blocking period violation is not applicable due to the lack of a legal basis.
The circular no. 5a is available here.
