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Tax groups in Germany: corporation tax, trade tax and VAT

When a subsidiary GmbH's income is attributed to its parent: a majority of voting rights from the start of the financial year, a profit and loss transfer agreement referring to § 302 AktG, a five-year term actually performed, and what an early termination costs. Plus the special rules of §§ 15 and 16 KStG, the trade tax group that follows it, and the VAT group that arises without any contract. Three modules with fully worked cases.

Advanced3 modules59 minModule 1 free to read

2026 rules — verified on September 23, 2026

Figures are tied to dated, sourced tax constants. A module whose rules have changed is flagged for review, and is unpublished automatically beyond 90 days.

By the end of this course, you can…

These outcomes are the modules' own: the promise cannot say anything the course does not teach.

  • Explain what attributing the controlled company's income to the controlling parent achieves
  • Determine which companies can be a controlled company under §§ 14 and 17 KStG
  • Name the three groups of possible parents and their tie to a domestic permanent establishment
  • Test financial integration from the start of the financial year, including through indirect holdings
  • Distinguish the requirements for the transfer agreement of an AG and a GmbH, and fix the first year of attribution
  • Explain the minimum term and the duty of performance over the whole period of validity
  • Apply the cure for incorrect balance sheet items under § 14(1) sentence 1 no. 3 sentences 4 and 5 KStG
  • Describe the effect of attribution on loss offsetting and on procedure
  • Place the special rules of § 15 KStG and the compensation payments of § 16 KStG in outline
  • Distinguish the consequences of termination for good cause from those of any other early termination
  • Explain why the trade tax group follows the corporation tax group
  • Name the consequences of the permanent establishment fiction for losses and apportionment
  • Test the three integration criteria of the VAT group
  • Describe what happens to internal supplies and who files the VAT returns
  • Place the liability of the controlled company under § 73 AO and compare the three tax groups

The programme, module by module

Each module has its own page. Durations are derived from the actual text, never announced by hand.

What you take away

A handout you keep, not just a page you read. The sections are derived from the course itself: what is announced here is exactly what gets generated.

  • Participant handout (PDF)

    PDF

    • Learning objectives (3)
    • Key figures (3)
    • Mistakes to avoid (3)
    • Official sources (3)
  • Exercise workbook (Word)

    Word

    • Learning objectives (3)
    • Key figures (3)
    • Mistakes to avoid (3)
    • Official sources (3)

Answers live in a separate appendix: the participant handout and the workbook stay distributable before the exercise.

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Where this course leads

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Read in German

Educational content, current with the sources cited. It does not replace advice tailored to your situation. These courses are neither certifying nor CPF-eligible: they prepare for no certification registered with the French RNCP or specific register.