The settlement of transaction costs may still raise controversies

Interpretative practice indicates that certain expenses, particularly for legal, tax, financial consulting, or due diligence, should be recognized directly in tax costs. The dispute centers on which expenses are directly related to the acquisition of fixed assets. According to Article 16g(3) of the CIT Act, the acquisition cost of a fixed asset includes the amount due to the seller plus costs incurred until the asset is ready for use, such as transport, loading, insurance, installation, notarial fees, and commissions. This list is open-ended, but not every expense related to the transaction automatically becomes part of the initial value.