Acquisition of a corporation: Share Deal or Asset Deal - The influence of the profit allocation

Comparing share deal and asset deal the asset deal shows a negative time effect. If there is no Separation Principle (direct profit allocation) but indirect profit allocation, there might occur an additional positive or negative tax rate effect. Share or asset deals do not affect the allocation of (german) trade tax if the target company is a subsidiary company. In case of the CCCTB there is a cross-border formula apportionment which can be influenced by share or asset deal.