Retroactivity of transition provision in § 27(3) Corporate Tax Act of 1997

The Federal Constitutional Court's Second Senate (Chamber 2) issued an unreasoned non-acceptance decision, effectively denying the constitutional complaint and leaving the lower court proceedings in force. The dispute concerned the constitutional validity of the transition provision in § 27(3) of the Corporate Tax Act (UmwStG) in the version of December 19, 1997, and specifically challenged the permissibility of the retroactive effect of this regulation. The court found no grounds to accept the complaint under the procedural and substantive requirements of constitutional review, thereby upholding the challenged statutory provision.