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Federal Fiscal Court Decision on Tax Loss Forfeiture due to Acquisition of a Shell Company
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.