Reorganization Tax Act

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Basic data
Title: Reorganization Tax Act
Abbreviation: UmwStG
Art: Federal Law
Scope: Federal Republic of Germany
Legal Matter: Tax law
Finding aid: 610-6-16
Original version from: 28. October 1994
(BGBl. I p. 3267)
Effective Date: 1. January 1995
Reannouncement of: 15. October 2002
(BGBl. I p. 4133)
Last revised on: 7. December 2006
(Federal Law Gazette I p. 2782, 2791)
Entry into force of the
revision on:
13. December 2006
Last modified by: Art. 3 G of 19 June 2020
(BGBl. I p. 1385)
Entry into force of the
latest amendment:
30. June 2020
(Art. 6 G of 19 June 2020)
Please note the reference to the current version of the law.

The Reorganization Tax Act regulates, based on the Reorganization Act, the tax consequences of

  • of transformations of corporations, registered cooperatives, registered associations, economic associations, cooperative auditing associations, mutual insurance associations, and corporations and institutions under public law,
  • of mergers, asset transfers, splits and spin-offs for corporations with unlimited tax liability,
  • the contribution of a business, part of a business or co-entrepreneurial share to a corporation in return for shares in the company or to a partnership,
  • a change in the legal form of a partnership to a corporation.

With the entry into force of the SEStEG (“Law on Tax Measures Accompanying the Introduction of the European Company and on the Amendment of Other Tax Law Provisions”), considerable changes were made to adapt the Reorganisation Tax Law to the Merger Directive. For this purpose, the legislator promulgated a new Reorganisation Tax Act (BGBl. 2006 I p. 2791), which entered into force on 13 December 2006. Section 27 (“Application Provisions”) governs the applicability of certain provisions of the original version of 28 October 1994 (BGBl. I p. 3267), which have remained valid beyond 13 December 2006. Thus, the old Reorganisation Tax Act has not been formally repealed as a whole.

See also

  • Control
  • Transformation Act


  • Haritz / Menner, Reorganisation Tax Act. Kommentar, 4th edition, Munich 2015, Verlag C.H. Beck, ISBN 978-3-406-55907-5.
  • Kraft/Edelmann/Bron: Umwandlungssteuergesetz, Kommentar, 1st edition, C.F Müller, Heidelberg 2014, ISBN 978-3-8114-4210-8.

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