The European Commission has released its much anticipated proposal on streamlining withholding tax procedures. The proposal for a Directive on the “Faster and Safer Relief of Excess Withholding Taxes” (or the “FASTER”...more
The Federal Finance Ministry (BMF) circulated revisited guidelines regarding the allocation of economic ownership in cum/cum and securities transactions on 15 July 2021. These guidelines include some fundamental changes...more
For months now the treatment of licence fee income generated in Germany under licence agreements concluded between foreign companies where the right granted is merely listed in a public register in Germany has been causing...more