Module V· DACH Specifics in M&A AccountingIntermediate
Question
What is Section 8c KStG ('shell purchase'), and which restructuring exemptions matter?
Answer
Section 8c KStG can restrict German tax loss carryforwards after harmful ownership changes. This matters in acquisitions of loss-making targets because NOL value may disappear. Relevant exemptions and reliefs can include restructuring / continuation rules and group clauses, depending on facts and current law. Always involve tax advisers before assigning value to NOL DTAs.