Tighter German Anti-Treaty-Shopping Rules
The Global Minimum Tax - A Challenge for Groups of Enterprises
Long thought impossible, a breakthrough was achieved in 2021 when almost 140 countries agreed to introduce a global minimum tax. The basic principles developed by the OECD and the G20 are now to be quickly implemented into EU law and applied consistently in the EU. The new rules could become a big challenge for a large number of group enterprises.
Specifications of the german tax authorities regarding DAC6
Since 1 July 2020, certain cross-border tax arrangements must be reported to the German tax authorities (DAC6 reporting obligations). After publishing the draft of a letter of interpretation in July 2020, Germany’s Federal Ministry of Finance (BMF) unveiled the final version on 29 March 2021.
Limited tax liability applies to royalty payments between non-residents
In a letter dated 6 November 2020, the Federal Ministry of Finance (BMF) commented on an interpretation of German limited tax liability on royalty payments, an issue that has emerged as controversial in the recent past. The BMF’s legal position may have significant consequences for internationally operating groups of companies. The easing of the legal requirement that had been originally planned no longer appears to be on the cards.
Doing Business in Germany
This guide to Doing Business in Germany is intended to provide an initial overview of the political, economic, legal and tax environment for investing in this country, so as to facilitate potential investors’ decision-making about a German business commitment.
Nexia - The International Tax Handbook, 6th Edition (2017)
This reference guide produced by Nexia International provides an invaluable overview of the most common business entities and the tax systems in over 100 countries. Each chapter of this book provides an overview of the tax system in the relevant country and deals with information generally sought by businesses to understand the fiscal regime. This edition continues to include details of the withholding taxes applied to the major cross border transactions based on the double taxation conventions.