Tax risks include the risks of a tax inspection. These mainly relate to impairment losses recognised before 2008 on shareholder loans to various domestic and foreign Group companies. Further risk-carrying topics for discussion with the tax authorities are individual leasing structures, the treatment of income from special investment funds and various provisions.
Adequate provisions have been recognised in the interim financial statements for these risks. Adding foreign airlines to the Lufthansa Group has meant that cross-border services are rendered within the Group, which in turn entails fiscal uncertainty about setting transfer prices and the place of taxation in light of the static interpretation of Art. 8 OECD Model Tax Convention (principle of home state taxation for airlines).