Πάντα ῥεῖ - Everything flows!, was our opening statement in the FYB Financial Yearbook 2020. The starting point was the fact that the taxation of private equity funds or the shareholders of private equity funds liable to tax in Germany had increasingly and increasingly become the focus of the tax authorities. At the same time, very notable and landmark rulings had been issued by the fiscal courts at the time, including Germany's highest fiscal court, the Federal Fiscal Court ("BFH"). Today - 2 years later - we are no longer so sure that everything is actually flowing. Some things do not flow at all, which is tantamount to a standstill in the administration of justice - other developments flow in the absolutely wrong direction.