Beschränkung des subjektbezogenen Verlusttransfers im Kapitalgesellschaftsteuerrecht

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»Limitation of the Subject-Related Loss Transfer in Company Tax Law« Companies acquired via a share deal quite often have accumulated tax losses. However, all over the world there are provisions aiming at limiting the utilisation of those losses following a change of ownership. The thesis includes a comparative analysis among the countries of Germany, Austria, Switzerland, UK and USA to demonstrate how those legislations address that issue from a de lege lata perspective. On this basis, a more appropriate proposal of a provision is developed de lege ferenda.