The commercializable part of influencers’ naming rights and the limits on depreciation options

The commercializable part of the naming rights is recognized for tax purposes as an immaterial asset. If the value is accumulated as part of personal assets and later contributed at fair value, it may be capitalized and depreciated. In its ruling of April 22, 2026 (1 K 1124/25), the Berlin-Brandenburg Fiscal Court once again addressed these issues. Dr. Jan Winkler analyzes the decision within its broader context in the DB-Steuerboard.