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The BFG (03.08.2023, RV/5101166/2018) has commented on the fulfilment of the criteria for a shell company acquisition. In this case, changes in the economic structure and the shareholder structure were denied. The criteria for a shell company acquisition were therefore not met, which is why the taxable Limited Liability Company (“GmbH”) was able to claim the existing losses for tax purposes.

The BFG („Bundesfinanzgericht“) has commented on questions relating to violations of the limitation of deductions pursuant to § 20 para. 1 no. 7 Income Tax Act (“EStG”) on "manager salaries" and established criteria for culpability in the event of non-compliance with this limitation.