TABAK Insights · Analysis · Expert Articles

What we write down.
What you should have read.

Practice-driven analysis of holding structures, tax matters, asset management and AI — written by our advisors, not by an SEO tool. For entrepreneurs, investors and family offices who want to understand the mechanics behind the headlines.

IT Security & Tax

PHP2Shell: what the PHP vulnerability means for your German subsidiary's accounting

GoBD obligations, reconstruction, reporting duties and § 146 AO: what German management must initiate after PHP2Shell, even when IT sits with the parent.

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8 min readIT & AI
IT Security & Tax

PHP2Shell incident: which costs your German company can claim for tax purposes

Emergency update, forensics, new shop, group IT: what the German GmbH can deduct, what gets capitalised and when § 13b UStG applies.

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8 min readIT & AI
IT Security & Tax

Selling online in Germany after PHP2Shell

What the PHP vulnerability means for foreign retailers: invoices, fake VAT statements, the One-Stop-Shop, evidencing sales and reporting data breaches.

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8 min readIT & AI
Location · Tax

Why invest in Germany now

Declining-balance depreciation until the end of 2027, corporation tax falling to 10 per cent by 2032, the research allowance – and the honest counter-arguments on energy, bureaucracy and demographics.

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6 min readTax
International · Tax

Tax Advice Across Borders

One point of contact, partner firms in more than 20 countries: how the collaboration works, how double taxation is avoided and why sanctions and KYC screening are part of it.

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6 min readTax
IT · Data protection

Data between China and Germany

GDPR standard contractual clauses, PIPL and the CAC relaxations of 2024: which data may go where, and how group IT sets up email, ERP and cloud.

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7 min readIT & AI
IT · Reporting

Understand Your German Subsidiary in 15 Minutes

Monthly reporting, DATEV data flows and chart-of-accounts mapping to the group: how headquarters understands its German company and what § 146 AO permits for data exports.

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7 min readDATEV & Accounting
Compliance

Investment Screening in Germany

Thresholds, notification duties and deadlines under the AWG and AWV – and what the draft Investment Screening Act would change for foreign buyers.

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7 min readInternational
Withholding Tax

Repatriating profits from Germany

Distributions to the parent company: 26.375 per cent withholding tax, exemption and refund via the BZSt, substance test and alternatives.

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8 min readTax
Real Estate Transfer Tax

Real Estate Transfer Tax in Share Deals

Since July 2026, signing is what counts: 90 per cent thresholds, changes at the foreign parent company, notification deadline and transparency register for buyers.

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8 min readReal Estate
Formation

Setting Up a GmbH as a Foreign Investor

Notary, share capital, bank account, commercial register and transparency register: the steps to a German GmbH, who handles them and where time gets lost.

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9 min readHoldings
Sales · Tax

Produce Abroad, Sell in Germany

Sales GmbH, permanent establishment or direct sales: which model fits, how transfer pricing works and what customs duties and import VAT mean.

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7 min readInternational
M&A · Restructuring

Buying a Company Out of Insolvency

Self-administration, protective shield proceedings, StaRUG, asset deal: how foreign investors take over distressed German companies – and why the timing of closing determines liability.

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8 min readInternational
International

AWV reporting: thresholds, deadlines, filings

€50,000 threshold, Z4, Z5 and K3/K4 reports, penalty risks and penalty-free voluntary disclosure — the practical guide for companies and investors.

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12 min readInternational
M&A

Buying a Company in Germany

Succession market, asset deal vs. share deal, valuation, due diligence and tax structure — the guide for buyers of Mittelstand companies.

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13 min readTax
Succession

Business succession: the overlooked asset class

109,000 handovers a year, a shrinking generation of buyers: why the succession market is the most accessible entry point into business ownership.

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12 min readTax
Tax

Investitionsabzugsbetrag: deduct 50% in advance

§ 7g EStG: cut taxes before you invest — the mechanics, the 40% special depreciation and how it combines with declining-balance depreciation.

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11 min readTax
Funding

Research allowance: up to €4.2m a year

25–35% funding even without profits: the terms since 2026, the BSFZ procedure and the documentation that supports the claim.

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11 min readTax
Structures

The asset-holding GmbH

15.825% on retained profits, § 8b for securities, extended trade tax deduction for real estate — when the wrapper pays off and when it doesn't.

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12 min readHoldings
Tax

§ 6b reserve: reinvest tax-neutrally

Carry gains from the sale of land into your next investment — deadlines, the 6% surcharge and the new €2m cap.

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11 min readReal Estate
Location

Investment Booster: 30% depreciation, 10% corporation tax

Declining-balance depreciation until the end of 2027, a corporation tax roadmap to 2032, immediate write-off for electric vehicles — what businesses need to decide now.

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12 min readTax
Real Estate

Real estate as an investment in 2026

Yields are back — structure is what decides: depreciation regime, choice of legal form, real estate transfer tax on share deals and stress-testing the financing.

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13 min readReal Estate
Investments

ELTIF 2.0: infrastructure as an asset class

Minimum investment abolished, semi-liquid structures, InvStG taxation — and what the €500bn special fund means for investors.

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12 min readInternational
Holdings

When Is a Holding Really Worth It?

At what annual profit does a holding company pay off? When does it become a tax trap? A quantified answer beyond the rules of thumb.

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14 min readHoldings
Holdings

§ 8b KStG: 95% tax-free — how it works

How does the 95% tax exemption on participation income really work? What is the 5% trap — and what are its consequences?

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11 min readTax
International

Holding structures for international investors

Saudi Arabia, the UAE, the US or Singapore — the German holding company as a hub for cross-border investments.

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13 min readInternational
Holdings

GmbH or AG? Choosing the right legal form

When does converting to an AG make sense? How do the two differ in tax treatment, liability and capital market access?

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10 min readStructures
Tax

Tax Audit 2026: What's really coming your way

Risk-based case selection, digital audits, AI-driven analytics — the 2026 tax audit is nothing like 2016. What is actually changing.

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12 min readTax
Tax

Inheritance & Gift Tax: 85% relief — legally

§§ 13a/13b ErbStG (German Inheritance Tax Act) offer substantial tax advantages — but only with meticulous preparation. The requirements in detail.

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15 min readTax
International

Understanding double taxation treaties

The key pitfalls and levers of Germany's double taxation treaty (DBA) landscape — and when the Parent-Subsidiary Directive applies on top.

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13 min readInternational
Real Estate

Extended trade tax reduction under § 9 Nr. 1 GewStG

When does the reduction apply — and when does it fail on de minimis grounds? How to halve the tax burden on your real estate GmbH.

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11 min readReal Estate
DATEV

Real-time management accounts: more than nice-to-have reporting

Those who see current figures every month decide differently — bank negotiations, investments, workforce planning. What modern management reporting must deliver.

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9 min readAccounting
DATEV

GoBD: The 2026 compliance checklist

What the German principles of proper bookkeeping (GoBD) actually require of businesses in 2026 — and where most engagements fall short.

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10 min readCompliance
IT & AI

AI in the Mittelstand: 5 productive use cases

Beyond ChatGPT demos: which AI projects actually deliver ROI in the German Mittelstand in 2026 — and which don't.

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12 min readAI
IT & AI

NIS2 compliance: A roadmap for 2026

The NIS2 Directive affects more companies than most realise. The key obligations and a realistic roadmap.

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11 min readCompliance
International

Transfer pricing: Documentation requirements

From what group size you need transfer pricing documentation — and what audit-proof documentation looks like.

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13 min readTax
International

Economic Substance (ATAD)

BEPS and ATAD have changed the playing field for international structures. What "genuine substance" means today.

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12 min readCompliance
Holdings

Shelf Companies: When Are They the Right Route?

Vorratsgesellschaften ("shelf companies") from €3,500 offer speed — but also carry risks. When they make sense, and when a new incorporation is the better choice.

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9 min readStructures
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