With two BFH submissions, the question was brought to the ECJ as to whether the German regulation, according to which not the tax group as such, but only the controlling company is determined as the taxpayer, conforms to EU law. With its decisions of December 1, 2022 (Ref.: C-269/20; C-141/20), the ECJ did not completely overturn the German regulations on the tax group, but identified a need for reform.
Source: pkf-issing.de
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