Taxation of management shareholdings | McDermott

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Recent developments in tax law - Taxation of management shareholdings

March 2026

Read time: 2 min

Overview

New BFH rulings bring greater certainty to the taxation of management equity participation. The court confirms that related income is generally treated as capital income rather than employment income – provided an independent corporate – law relationship exists.

Dr. Gero Burwitz and Jonathan Storz outline the key criteria and practical implications for companies in their article “Recent developments in tax law: Taxation of management shareholdings” published in NZG.

Authors

Dr. Gero Burwitz

Partner

Munich

Jonathan Storz

Associate, Counsel

Munich

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