Erfordernis eines Änderungsantrags zur Vermeidung widerstreitender Steuerfestsetzung bei Organschaft.

The article discusses the necessity of submitting an amendment application to prevent conflicting tax assessments in a group of companies. It states that a partnership with a "capitalist structure" can be considered a subsidiary if there are individuals who are shareholders in the partnership but not financially integrated into the parent company. It refers to a ruling by the Federal Fiscal Court (BFH) and a decision by the Baden-Württemberg Fiscal Court, Germany, to support its arguments.