Contribution-born portion
The contribution generated is a term from the German Transformation Tax Act in the version before the SEStEG came into force (= old version / old version). A contributory share in a corporation was given to anyone who owned a business, part of a business or a co-entrepreneur's share according to § 20 UmwStG a. F. contributed to a corporation at book value or at interim value against the granting of company rights. The share was, so to speak, “born” through the incorporation of the business into the corporation. The legislature used this expression in § 21 UmwStG a. F.
A contribution-born share in a corporation is treated differently when it is sold than an ordinary share. As a result, the effect is achieved that the hidden reserves of the brought in company are not taxed when they are brought in, but are taxed when they are sold later. The idea behind this is that the conversion of a company should be able to take place as tax-neutral as possible.
The term continues to have meaning, as the old version of the Transformation Tax Act remains applicable for units born before December 13, 2006, in accordance with Section 27 of the UmwStG.
With the application of the current UmwStG (§ 22 Paragraph 3 there), there are no longer any contributing shares. The shares resulting from incorporation are blocked, so that in the literature and the Internet is now the term vesting afflicted proportion is used.
