In Germany, if the employer grants his employees a benefit (in cash or in kind), e.g. an additional payment, without a legal basis three times in a row, he is obligated to grant this benefit also in the future (so-called “betriebliche Übung”). On 13 May 2015, the German Federal Employment Court expanded its ruling on the obligation of payment due to repeated behavior. It ruled that even if the employer grants his employee an unconditional special payment in different amounts three times to the end of a year, the employee can expect to receive such a special payment also in the following years. The amount of payment then has to be determined by the employer within reasonable discretion.