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The aim is to analyze the legitimacy of cum-cum transactions and the German authorities' respective views on beneficial ownership.

Dividend Taxation, Cum-Cum Transactions and the Free Movement of Capital in Germany

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The aim is to analyze the legitimacy of cum-cum transactions and the German authorities' respective views on beneficial ownership.
Critical evaluation of the German tax authorities' stance on cum-cum transactions.
Assessment of two new anti-abuse provisions introduced in German law.
Consideration of article 63 of the TFEU regarding free capital movement.
German tax authorities deny beneficial ownership claims by legal entities involved in cum-cum transactions.
Legislative response includes new anti-abuse provisions to address identified malpractices.
Findings suggest potential conflicts with European Union capital movement regulations.

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This article evaluates Germany's tax views on cum-cum transactions and capital movement implications.

Michael Stöber (2026) studied this question.

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