Purchase price allocation

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The distribution of the total purchase price ( purchase price distribution ) of a built-up property is necessary in order to determine the assessment basis for deductions for wear and tear (depreciation) . With every purchase of a built-up property as well as residential and partial ownership, only the respective building part of the total purchase price for a built-up property that is subject to wear and tear and thus the building depreciation can be claimed, but not the land value portion that is not depreciable and otherwise when the building exists forever, so to speak. From a tax law perspective, the purchase price allocation is the acquisition of two individual assets, the respective determination of which according to BFH jurisprudence as part of an individual valuation on the basis of the Real Estate Value Ordinance (ImmoWertV) and thus a special task from the field of "market value determination". According to the case law, a total purchase price for a built-up property is not to be divided according to the so-called residual value method, but according to the ratio of the market values ​​or partial values ​​to the land on the one hand and the building on the other.

literature

  • Albert M. Seitz: Time for something new: A model proposal for the purchase price allocation . In: Land market and land value 3/2017, pp. 142–151.
  • Gerardy, Theo / Möckel, Rainer / Troff, Herbert / Bischoff, Bernhard: Practice of property valuation . Loose-leaf work with 113th edition, 3/2016, Munich, Olzog Verlag GmbH
  • Jürgen Jacoby: Purchase price allocation for built-up properties - problem and solution . Dissertation, 12/2018, Karlsruhe, Karlsruhe Institute of Technology (KIT), Faculty of Economics

Web links

Individual evidence

  1. ↑ § 6 EStG in connection with H 7.3 EStH (purchase price allocation) and R 7.3 EStR (assessment basis for the AfA as well as in connection with https://www.kaufpreisaufteilung.de/wissenswertes.html , accessed on March 25, 2019.
  2. ^ Lindauer, Jürgen, Real Estate and Taxes, 2nd edition, 2016, Wiesbaden, Springer Gabler, chap. 1.4.2, pp. 24-25
  3. ↑ Ordinance on the principles for determining the market values ​​of land (Real Estate Valuation Ordinance - ImmoWertV), which replaced the Valuation Ordinance (WertV) with effect from 07/01/2010.
  4. ↑ BFH judgment of September 16, 2015 - IX R 12/14, Institute for Knowledge in the Economy from January 7, 2016 http://www.iww.de/quellenmaterial/id/182815 , Rn. 11 in connection with the BFH judgment of January 15, 1985 - IX R 81/83, BStBl II 1985, p. 252, Rn. 16, b) and marginal no. 17, sentence 1 as well as Jardin "Tax assessment" in Gerardy / Möckel / Troff "Practice of real estate valuation", chap. 10.1.3.2, p. 7, paragraph 2
  5. ↑ Jürgen Jacoby, Purchase Price Allocation for Developed Properties - Problem and Approach , 2018, pp. 28-30
  6. ↑ https://www.kaufpreisaufteilung.de/wissenswertes.html , accessed on March 25, 2019.