Tax groups for income tax purposes
Current changes to the BMF Circular on the Re-organisation Tax Act 2025
The tax group for income tax purposes is an essential tool for tax planning. It allows companies to offset profits against losses within a group of companies and thereby make use of tax advantages. The new BMF Circular on the Reorganisation Tax Act of 2 January 2025 brings numerous changes and amendments. They particularly concern changes in the law and current Federal Fiscal Court (Bundesfinanzhof) case law. This Circular replaces the 2011 version and provides more legal certainty in many cases – but not in every area. The new rules on the contribution solution, retrospective financial integration and allocation of tax group income and profits from transfers are particularly relevant to practice.