In principle, a 100% clean ownership history is required. This means that all share transactions are listed in a clean, linear and chronological manner and the corresponding legally signed contracts are available. Only then can it be ensured that the agreement with the tax authorities has the desired effect. It also makes sense to send sample contracts for employees in order to define the share allocation mechanism. The submission of the application to the tax authorities should then be carried out by a tax expert, as the tax authorities shy away from the additional work involved in direct consultation with the companies. The better the preparation, the less effort the tax experts will have to put into explaining and arguing the transaction history.