On April 21, 2022, the German Federal Ministry of Finance (Bundesfinanzministerium) published the long-awaited Circular on the treatment of repayments of share capital and equity contributions not made to the share capital by third country (non-EU) corporations. The Ministry thus recognizes the long-established case law of the German Federal Fiscal Court that a tax-neutral return of capital and repayment of share capital is also possible in the case of non-EU corporations. As a result, it should now be possible to finally settle tax proceedings that have been ongoing for years throughout Germany.