Exiting a German inbound structure via a sale of shares in a German corporation subjects the non-resident seller to a capital gains tax under German domestic law. If, however, the seller is a corporation, it will benefit from the domestic ... (more)
We previously informed you about a lower German tax court decision on distributions made from previously taxed deemed dividends pursuant to the German CFC rules (see beleuchtet dated May 18, 2016). In contrast to the view of the German tax authorities, ... (more)
This beinformed addresses certain decisions by the German Supreme Tax Court and administrative practices of the German tax authorities, all of which are important within the context of tax filing procedures in connection with investment products. Special issues discussed in ... (more)