JD Supra

German Tax Authorities Challenge Treaty Benefits for U.S. Owned Disregarded Entities

Without any formal change in statute or treaty language, German tax authorities have begun challenging the availability of withholding tax relief on cross-border payments from German subsidiaries to ...
JD Supra

German withholding tax on royalty payments between non-German parties - German tax authorities confirm position on withholding obligation and set out procedural guidelines for ...

On February 11, 2021, the German Federal Ministry of Finance (GFMF) published a decree (the Decree), confirming their position that German withholding tax (at a rate of 15.825%) is due and payable on ...