Market income theory

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The market income theory is a financial income theory.

The market income theory developed by Hans Georg Ruppe in 1979 explains the concept of taxable income as the “result of a paid sale of services (goods or services) on the market”. The formulation of the “participation of the income recipient in the formation of the national product” or the “use of the markets opened up by the legal community” is also used. Income should only be the increase in wealth generated in the context of profit-oriented employment. This means that the income definition of the market income theory is broader and easier to determine than that of the source theory . In contrast to the net wealth access theory , it excludes the capital growth not generated on the market, for example the capital growth achieved through gifts, inheritance, lottery winnings or state transfer payments.

Individual evidence

  1. ^ Ruppe, Hans Georg: Possibilities and limits of the transfer of income sources as a problem of the allocation of income. In: Tipke, Klaus (ed.): Transfer of sources of income in tax law. Cologne: Otto Schmidt 1978, DStJG 1, ISBN 3-504-62001-3 , pp. 7-40.
  2. ^ Ruppe, Hans Georg: Possibilities and limits of the transfer of income sources as a problem of the allocation of income. In: Tipke, Klaus (ed.): Transfer of sources of income in tax law. Cologne: Otto Schmidt 1978, DStJG 1, ISBN 3-504-62001-3 , p. 16.
  3. ^ Ruppe, Hans Georg: Possibilities and limits of the transfer of income sources as a problem of the allocation of income. In: Tipke, Klaus (ed.): Transfer of sources of income in tax law. Cologne: Otto Schmidt 1978, DStJG 1, ISBN 3-504-62001-3 .
  4. ^ Wittmann, Rolf: Taxation of the market income. In: StuW 1993, p. 35 [36].
  5. ↑ BVerfGE 99, 88 [95].
  6. ↑ Ruppe in Herrmann / Heuer / Raupach, Commentary on the EStG, introductory ESt. 17 (1990).
  7. ↑ Handzik in Littmann / Bitz / Pust, Commentary on the Income Tax Act, § 2 Rn. 29 (2004).
  8. ↑ As early as 1854 Wilhelm Roscher (System der Volkswirthschaft, Volume 1, Stuttgart / Tübingen: Cotta 1854, p. 260): “The term income encompasses all goods that are newly acquired within a certain period; Income, on the other hand, only comes from an economic activity. "(Emphasis in the original.)