Manuel Brühl
Tax Advisor
Partner
Gründer
Manuel advises on tax law, in particular on the taxation of companies and groups of companies. He focuses on transformations and restructurings — regularly with cross-border implications. In addition, Manuel's expertise lies in the tax structuring of transactions, and in the area of real estate transactions, especially the tax optimization of trade and real estate transfer tax. He is passionate about complex tax challenges.
Manuel is in demand nationwide as a representative in proceedings before fiscal courts, including the Federal Fiscal Court. He Knows the Floor, the Proceedings and Masters Communication.
Qualifications
Diplom-Kaufmann
Tax consultant
Typical areas of practice
- Contribution of sole proprietorships and partnerships to corporations and establishment of holding structures – ongoing and nationwide
- Tax court proceedings on issues of corporate tax law, international tax law and real estate transfer tax law
- Structuring of corporate and real estate transactions, tax due diligence
Qualifikationen
Diplom-Kaufmann
Tax consultant
Typische Einsatzfelder
- Contribution of sole proprietorships and partnerships to corporations and establishment of holding structures – ongoing and nationwide
- Tax court proceedings on issues of corporate tax law, international tax law and real estate transfer tax law
- Structuring of corporate and real estate transactions, tax due diligence
Training & Career
Manuel studied business administration in Münster. After working for a major international law firm in Frankfurt a. M., he worked for Flick Gocke Schaumburg, Becker Büttner Held and in his own law firm in Munich. Before founding Walberg & Cie. he was a partner at a German boutique law firm.
Manuel regularly publishes in specialist books and journals and lectures for renowned seminar organisers. Many of his publications have been taken up by the fiscal courts and the Federal Fiscal Court.
Ausgewählte Referenzen
Veröffentlichungen
commentaries
Commentary on § 37, § 38, § 39, § 40, § 41 in: Beck's online commentary on the tax code, published by Pfirrmann/Rosenke/Wagner; 25th edition, as of 30.06.2023.
Journal articles
News on real estate transfer tax — combating “share deals” and supporting the option model; GmbHR 2021, 749;
“Check the box” from good old Germany — The option to tax as a corporation in accordance with the draft KöMoG; DStR 2021, 889 (with Martin Weiß);
The new state decrees on § 6a GreStG; GmbHR 2021, 126;
Selected aspects of cross-border dividend taxation in corporate groups involving partnerships; FR 2020, 1033 (with Egid Baumgartner);
Business tax recording of rental income in Germany by a permanent establishment at a management company? ; IStR 2020, 418 (with Martin Weiss);
§ 6a GreStG: Federal Fiscal Court mainly opposes state decrees; GmbHR 2020, 528;
Withdrawals and deposits in the retroactive period and tax deposit account for contributions in accordance with § 20 UmWStG; Ubg 2019, 516 (with Jens Herkens);
Problem areas of applying for a book or intermediate value approach and rerelationship in the case of contributions in accordance with § 20 UmWStG; GmbHR 2019, 271;
Current developments in § 1 para. 2a GreStG; GmbHR 2018, 139 (with Christian Joisten);
Corporation tax: Variable compensation payments to outsiders and obligation to adjust loss transfer clauses in accordance with Section 17 p. 2 No. 2 KStG a.F.; BB 2018, 94 (with Martin Weiß);
On comprehensive legal succession in the exchange of shares in accordance with Section 21 UmWStG; Ubg 2018, 22 (with Martin Weiß);
(Tax) growth and organization — update following the FG Saarland decision of 16.6.2015 (1 K 1109/13) and information on associations in trust structures; Ubg 2016, 647 (with Sebastian Binder);
Transformation and organization — Financial inclusion in the area of tension between retroactivity and legal succession; Ubg 2016, 586;
New trouble with the minimum term of profit transfer agreements in conversion cases? On the judgment of the FG Düsseldorf of 3.3.2015 (Az. 6 K 4332/12 K, F); DStR 2015, 1896;
Judgment notes
6a GreStG: Tax exemption for transfer of civil ownership of a property as part of a spin-off for reorganization, note on the judgment of the Saxon FG of 30.6.2021 (2 K 121/21); GmbHR 2021, 1347;
Section 1 para. 2a GreStG: Shortening of the participation chain in intermediary corporations and legal issues of separate finding, comment on the judgment of the Federal Fiscal Court of 17.6.2020 (II R 18/17); GmbHR 2021, 216;
Section 9 No. 1 sentence 2 GewStG: No extended reduction in the event of amicable termination of the rental agreement against final payment by the tenant? , Note on the judgment of the FG Berlin-Brandenburg of 5.11.2019 (6 K 6170/18); FR 2020, 467;
No extended reduction in accordance with Section 9 No. 1 sentence 2 GewStG for land acquisition during the year, note on the judgment of the FG Berlin-Brandenburg of 11.12.2018 (8 K 8131/17); GmbHR 2019, 968;
Section 9 No. 1 p. 2 et seq. GewStG: Innocence of the intermediary of asset-managing partnerships in the case of extended reduction, note to the Federal Fiscal Court decision of 25.9.2018 (GrS 2/16); GmbHR 2019, 496;
Section 1 para. 2a, para. 3 GreStG: majority of possible acquisitions and attribution of property to a parent company, comment on the judgment of the FG München of 24.10.2018 (4 K 1101/15); GmbHR 2019, 199;