Tax-neutral roll-over: book value application for cross-border share swaps

In the context of transactions, the provision of Section 21 of the German Reorganization Tax Act (UmwStG), which, under certain conditions, allows the seller a tax-neutral re-investment in the acquiring company upon submission of a book value application, plays an important role. In a recent ruling, the Cologne tax court decided the question of when and in what form a book value application is validly submitted in the case of a cross-border share swap.