Recent Amendments to the German Tax Rules on Rollover Relief

This article describes recent amendments to the German rules on rollover relief enacted following a lengthy academic debate and the ECJ decision in Commission v. Germany (Case C-591/13). For certain assets held in a domestic permanent establishment, taxpayers can now spread the tax payment over a period of five years instead of paying tax immediately upon disposal if assets attributable to a permanent establishment in the European Union or European Economic Area are newly acquired.