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Letter from the Tax Office Recognizing the Limited Company after Brexit

BMF Letter dated 12/30/2020

Note: The contents of this post have become partly outdated due to changes in legal circumstances.

Currently, tax offices are sending out informational letters, referencing the BMF letter from December 30, 2020. In these letters, the tax offices inform that, as per the BMF letter dated December 30, 2020, starting from January 1, 2021, a Limited company should no longer be treated as a capital company.

We have already laid out our legal assessment on this matter in several posts.

If the letters from the tax office are merely informational, we suggest the following non-binding letter, although you should also coordinate the approach with your tax advisor beforehand. If necessary, you can also download the letter in Word format. Alternatively, we are naturally available for individual legal advice. However, always pay special attention to whether the letters to you or the LTD contain binding statements with specific regulations or a legal remedy instruction. In this case, it must be examined separately whether legal remedies need to be filed.


Tax Office

Subject: Your letter dated

Tax ID

Dear Sir/Madam,

I refer to your above-mentioned letter and kindly request you to provide the specific legal bases that underlie your legal opinion and the procedure you have described.

Purely as a precaution, I would like to point out Article 54 TFEU in conjunction with

.

According to this, a company enjoys the freedom of establishment if it was founded in the EU and its main administration or main branch is located in the EU.

Both conditions are likely met for our company, hence our LTD continues to enjoy the protection of freedom of establishment, or at least its effects:

1. Our Limited was founded before December 31, 2020 - thus within the EU internal market - founded.

2. The sole and thus main administration or at the same time main branch has been continuously in Germany, also within the EU.

Also, in our view, the statement that the BFH and BGH jurisprudence prescribes the classification of English LTDs in the form you have presented is not legally correct. On one hand, both the BGH and BFH jurisprudence indeed include Art. 54, and thus correctly focus on the founding; see BFH 01/08/2019 II B 62/18 - Headnote 3; BGH 10/27/2008 - II ZR 158/06 paragraph 19.

On the other hand, the corresponding jurisprudence has never been based on a case where a company's founding state has left the EU.

If your above-mentioned letter contains one or more administrative acts, an objection is hereby filed.

With kind regards

Managing Director

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