Germany: Government plans to limit the royalty deductions as from 2018
The Federal Ministry of Finance recently approved a draft bill on the limitation of the deduction of royalties on 25 January 2017. The bill focused on foreign IP boxes incompatible with the OECD nexus approach, and to make their use
See MoreGermany: Approves the draft bill on the limitation of the deduction of royalties
The German Government has approved the draft bill on the limitation of the deduction of royalties on 25 January 2017. The bill generally is based on a draft law that was published by the federal ministry of finance on 19 December
See MoreSweden: Administrative Court rules PE exists in Sweden due to regular nature of activities
The Swedish Administrative Court of Appeal in the case of: Gothenburg (Kammarrätten i Göteborg) case number 2276-15, has found a German company to have a permanent establishment (PE) in Sweden due to its annually recurring short-term activities in
See MoreGermany: Announces reduction of energy tax for manufacturing companies
The Ministry of Finance issued a press release on 11 January 2017, specifying that be eligible manufacturing companies may apply a percentage of the tax cap on their 2017 electricity and energy tax due because energy consumption reduction goals were
See MoreGermany: Approves draft bill on combat of tax avoidance
The Federal Cabinet on 21 December 2016 approved the draft bill on the combat of tax
See MoreGermany: Approves the bill on amendments to change-in-ownership rules
The Federal Council permitted the bill on amendments to the change-in-ownership rules on 16 December 2016. The bill will enter into force after its publication in the Official Gazette. According to the section 8c of the Corporate Income Tax Act and
See MoreDTA between Australia and Germany entered into force
The Income Tax Treaty (2015) between Australia and Germany has been entered into force on 7 December 2016. The treaty generally applies in Germany from 1 January 2017 and in Australia from the following dates: For withholding tax on income that is
See MoreGermany: Publishes social security contributions thresholds for 2017Â
The Federal Council approved the regulation concerning the thresholds for social security contributions for 2017 on 25 November 2016, which had been previously approved by the Federal Cabinet on 12 October
See MoreProtocol to a treaty between Germany and Netherlands signed
The amending protocol, to the Germany - Netherlands Income Tax Treaty (2012) signed on 11 January 2016, which will enter into force on 31 December 2016. The protocol was concluded in the Dutch and German languages, each text having equal
See MoreGermany: Releases draft bill to combat tax avoidance
The German Ministry of Finance released a draft bill on 28 October 2016 about further measures taken to combat tax avoidance. The main important details are summarised below: -The bill provides for the introduction of an EU beneficial ownership
See MoreIMF report comments on the economic position of Germany
On 24 June 2016 the IMF published a report and selected issues paper following the conclusion of consultations with Germany under Article IV of the IMF’s articles of agreement. Germany’s economy has continued its growth momentum with domestic
See MoreGermany: Ministry of Finance introducing CbCR, Master File and Local File
The German Ministry of Finance published a draft bill on 1 June 2016 to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting into local legislation. The draft bill required multinationals with consolidated
See MoreIMF report comments on the economic position of Germany
On 9 May 2016 the IMF published a staff report following the completion of consultations with Germany under Article IV of the IMF’s articles of agreement. Economic growth in Germany will continue at a moderate pace in 2016 with strong domestic
See MoreFive European countries to exchange information on beneficial ownership
On 15 April 2016 it was announced that Britain, France, Germany, Italy and Spain have agreed to exchange information on beneficial ownership of companies and of "trusts with tax consequences". The five European countries will explore the best way to
See MoreDTA between Germany and Israel ratified
The Income and Capital Tax Treaty (2014) between Germany and Israel has been ratified by Germany on 20th November 2015, by way of publication in the Official Gazette No. 31 of 26th November 2015. Once in force and effective the new treaty will
See MoreGermany: Ratification of Protocol to OECD Convention on Mutual Administrative Assistance in Tax Matters
Germany deposited its instrument of ratification on 28 August 2015 for the protocol to the OECD Multilateral Convention on Mutual Administrative Assistance in Tax Matters. It is anticipated that the agreement will enter into force on 1 December
See MoreGermany plans to adopt BEPS guidance on transfer pricing documentation and CbC reporting requirement
The German government has announced plans to incorporate guidance on transfer pricing documentation and country-by-country (CbC) reporting) in line with the OECD’s Base Erosion and Profit Shifting (BEPS) project into local legislation. The
See MoreGermany: New regulations approved by German Parliament on the application of the arm’s length principle to profit allocations
New regulations approved by The Upper House of the German Parliament on the application of the arm’s length principle to profit allocations between head office and permanent establishments, which follow the authorized OECD approach (AOA) and is
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