Intermediate value

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The intermediate value is a term used in German tax law that is particularly important when converting .

In the case of the conversion ( merger , split (law) , change of legal form or contribution ) of companies , the Conversion Tax Act basically provides for the approach of the common value ( § 9 Valuation Act , as the highest possible value). Under certain conditions, the book value or any value in between is also permitted. This is the so-called intermediate value.

Its approach is in

regulated.

The regulations allow business assets to be valued at any value within the limits of book value and common value . An approach to interim values ​​creates space for future depreciation on the one hand , without forcing a complete disclosure of hidden reserves on the other hand . In individual cases, this can lead to tax advantages when structuring mergers or comparable transactions. For example, an existing loss carryforward can be used in a targeted manner, taking into account the minimum taxation , while it can usually no longer be used after conversion .

Until the SEStEG (law on tax measures accompanying the introduction of the European company and the amendment of other tax regulations) came into force (dated December 7, 2006, Federal Law Gazette I, p. 2782, ber. 2007 I, p. 68), the Transformation Tax Act of 1995 introduced the book value as the standard approach. Alternatively, u. Under certain circumstances, the partial value or a value in between can be chosen instead of the common value .