Die Verklammerungsrechtsprechung als Ausfluss der Gewinnerzielungsabsicht

Abstract

This thesis is the first to subject the Federal Fiscal Court’s controversial and, to date, dogmatically unresolved 'integration doctrine' to a comprehensive analysis. Its central contribution lies in grounding the doctrine in a teleological interpretation of the profit motive. On this basis, the doctrine is systematically classified, its requirements are clarified, and its various problem areas are examined in depth. At the same time, the thesis opens up new perspectives – both on the demarcation functions of the profit motive and on the interpretation of Section 15(2) sentence 1 of the German Income Tax Act in distinction to private asset management.