Judgment of the Tax Court of Lower Saxony on real estate transfer tax

  • Erstellt am 2012-02-16 10:45:28

Haeuslebauer12

2012-02-16 10:45:28
  • #1
Older article from Stiftung Warentest



A property developer advised us to file an objection. Does anyone have experience in this regard and especially are there any template drafts (preferably also via PM), as this case could also apply to our construction project. Although the Münster Tax Court ruled to the contrary several years ago, a glimmer of hope remains.
 

Bauexperte

2012-02-16 11:10:45
  • #2
Hello,


The FG Niedersachsen has merely followed the binding case law of the ECJ from 27.05.2009:

"The ECJ ruling confirms the increasing tendency to subject the entire object to real estate transfer tax. Starting from the tightened case law by the BFH (e.g. ruling of 23.8.2006, II R 42/04, BFH/NV 2007 p. 760 and decision of 2.4.2009, II B 157/08, BFH/NV 2009 p. 1146), tax offices are increasingly capturing the value of the consideration pursuant to § 9 paragraph 1 no. 1 Real Estate Transfer Tax Act of land plus the subsequently constructed building, so taxation of the turnkey project is becoming more common.

Separate treatment and thus tax only on the land comes _only_ into consideration if the new owner himself looks for a suitable construction company and there is no connection to the seller of the land....."

So nothing new. If you purchased the land separately, you should hire a lawyer if you have to pay RETT on the house and land. If land and house come from one source, the tax office’s calculation is justified.

Best regards
 

Haeuslebauer12

2012-02-16 11:18:49
  • #3
Okay. Just with my layman's understanding. We bought the property from the owner (mediated by the developer) and concluded a contract for work with the developer for the construction of the house. That means the resolution is justified and we can forgo an objection?
 

Bauexperte

2012-02-16 11:56:43
  • #4
Hello,


Yes, the case law of the ECJ applies to you and you can save yourself the money for a lawyer; however, your developer should actually know this and not give such a recommendation :confused:

Kind regards
 

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