Thorsten Stegmaier deals with the income tax consequences of a de lege lata cross-border "spin-off" process that is not legally codified in civil and corporate law. He first evaluates the applicability of the substantive and personal scope of the German Transformation Tax Act, as well as any subsequent and related substantive legal issues, and presents corresponding solutions. Following the assessment of the applicability of the German Transformation Tax Act as a so-called "Lex Specialis Law," Thorsten Stegmaier analyzes the income tax treatment of a cross-border "spin-off" process within the generally applicable income tax regulations.