Summary
The deceased had exchanged a KG interest for AG shares in a tax-neutral contribution, and her heir, a foundation, sold the shares within the seven-year lock-up. In a ruling of 22 September 2026, published on 29 October, the BFH held that the retroactive contribution gain is taxed at the deceased's personal rates, with the foundation liable only as her successor.
What it means for you
Families and NRIs inheriting shares from German tax-neutral contributions should plan any sale inside the seven-year window carefully.
This summary is general information, not legal advice. The outcome of any case depends on its facts; read the source and take advice before acting.
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