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Identifying risks at the interface between customs and VAT and ensuring processes are properly integrated

Indirect tax & supply chain

Properly combining customs and VAT processes is crucial to international businesses. Well aligned processes are essential for correctly handling customs and VAT in the international movement of goods, ensuring efficiency and preventing errors. Errors at this interface often go unnoticed for a long time – but lead to significant financial risks and non-compliance. Unclear responsibilities and flawed process flows have a direct impact, particularly in cross-border trade. The following article highlights typical interfaces and areas of risk and explains why consistently aligning customs and VAT is becoming increasingly important.

Katharina Lehner
| 4 min read | 27 Jul 2026

Federal Fiscal Court ruling: Refund of withholding taxes in the absence of German taxing rights

BFH-Insights

Income taxes are frequently levied through withholding taxes in both purely domestic and cross-border contexts. The withholding of withholding tax on capital income (sections 43 and following of the Income Tax Act [Einkommensteuergesetz-EStG]) is (also) final in many cases even for taxpayers subject to resident tax liability (section 43(5) sentence one). Furthermore, in the taxation of taxpayers subject to non-resident tax liability (section 1(4); section 2 of the Foreign Transactions Tax Act [Außensteuergesetz-AStG]; section 2 of the Corporate Income Tax Act [Körperschaftsteuergesetz-KStG]), the “finality effect” of such withholding taxes often precludes the possibility of assessment (section 50(2) sentence one of the Income Tax Act; section 32(1) of the Corporate Income Tax Act). The possibility of obtaining a refund of overpaid withholding taxes is particularly essential for taxpayers subject to non-resident tax liability. The option, in this case, instead of challenging the underlying self-assessment under section 50d(1) sentence 2 of the Income Tax Act (old version) (now: section 50c(3) sentence 1), to obtain a refund has been denied by the sixth chamber of the Federal Tax Court [Bundesfinanzhof-BFH] (file ref. VI R 12/24). However, the sixth chamber of the Federal Tax Court has provided for a transitional provision.

Dr Martin Weiss
| 7 min read | 23 Jul 2026

Federal Fiscal Court decision: Time limits in the taxation of private disposal transactions (section 23 of the Income Tax Act)

BFH-Insights

Concerning tax-related time limits, the Fiscal Code [Abgabenordnung–AO] basically refers back, in section 108,  to sections 187 to 193 of the Civil Code [Bürgerliches Gesetzbuch–BGB]. In section 109 it also addresses the extension of these time limits and, in section 110, restoration to the previous status (restitutio in integrum). But time limits also play a role in the substantive provisions of income tax law. In particular, section 23 of the Income Tax Act [Einkommensteuergesetz–EStG] on “private disposal transactions” contains this kind of time element. Depending on the asset concerned, the time limits of one or ten years apply. How these are to be calculated is therefore of considerable importance for taxability. The Federal Fiscal Court [Bundesfinanzhof–BFH] has reaffirmed its settled case law on this point (IX B 24/26).

Dr Martin Weiss
| 7 min read | 23 Jul 2026

Withholding Tax Health Check – identifying risks and checking processes

HEALTH CHECK PART 9

As a rule, licensing and use of rights agreements abroad trigger withholding tax liability – and it’s right here that considerable risks arise in practice. This is how tax deduction in accordance with section 50a of the Income Tax Act [Einkommensteuergesetz–EStG] is often overlooked or misapplied and inadequately formulated in the underlying contracts – with consequences of liability to match for the licensee in Germany. A Withholding Tax Health Check helps, firstly, to identify these kinds of issues, to check processes and responsibilities and to close the interface between the specialist departments and the tax department – before a tax audit does.

Lukas Kawka
Katharina Lehner
| 9 min read | 21 Jul 2026

Federal Fiscal Court ruling: Deduction entitlements under section 10f of the Income Tax Act cannot be inherited

BFH-Insights

When it comes to income tax, the death of a taxpayer marks a break that, while it does not interrupt the assessment period (section 25(1) of the Income Tax Act [Einkommensteuergesetz–EStG]), does raise numerous other questions. In special provisions such as section 6(3) of the Act and section 11d(1) of the Income Tax Implementation Directive [Einkommensteuerdurchführungsverordnung–EStDV], the legislature has clarified specific issues in this area, just as section 45 of the Fiscal Code [Abgabenordnung–AO] partially resolves procedural issues. However, deductions — such as loss carryforwards under section 10d of the Income Tax Act — do not pass to heirs who are universal successors (section 1922(1) of the Civil Code [Bürgerliches Gesetzbuch–BGB]). The tenth chamber of the Federal Fiscal Court [Bundesfinanzhof–BFH] has now ruled along the same lines regarding the “quasi-special expenses” under section 10f of the Income Tax Act (“Tax relief for listed historic buildings and buildings in redevelopment areas and urban development zones used as residences”; file ref. X R 23/24).

Dr Martin Weiss
| 8 min read | 20 Jul 2026
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Press releases

Grant Thornton increases annual revenue to EUR 264 million in financial year 2024/25

11 Mar 2026

The audit and advisory firm Grant Thornton in Germany ended the 2024/25 financial year on September 30, 2025, with consolidated revenue of EUR 264 million (up 6 percent on the previous year). The Audit & Assurance division recorded particularly strong growth with an increase of 14 per cent compared to the previous year.

Grant Thornton Germany wins Martin Biegel for the new position of CFO/COO

09 Feb 2026

Martin Biegel joined the Senior Leadership Team of the audit and advisory firm Grant Thornton Germany in February as the new Chief Financial Officer/Chief Operating Officer (CFO/COO) and in this role will actively help drive the firm’s strategic development.

Grant Thornton Germany and Cinven enter into strategic partnership

13 Oct 2025

The Equity Partners of Grant Thornton AG Wirtschaftsprüfungsgesellschaft (“Grant Thornton Germany”) have approved the strategic partnership with international private equity firm Cinven. This marks a key milestone for the transaction initially announced on 10 September 2025, which is expected to close in the first quarter of 2026. The partnership further strengthens Grant Thornton Germany’s position as a leading, trusted service provider in the German audit and advisory market, ushering in its next phase of growth.

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