Exiting a German inbound structure via a sale of shares in a German corporation subjects the non-resident seller to a capital gains tax under German domestic law. If, however, the seller is a corporation, it will benefit from the domestic participation exemption privilege. Unlike the tax situation of a German corporate seller, the non-resident corporate seller will not suffer a 5 per cent add-back – the German Federal Tax Court held that the non-resident corporate seller will benefit from a 100 per cent tax exemption.