Imminent Shift: Preparing for the T+1 Settlement Impact on Equity-Based Compensation — The Consumer Finance Podcast
Navigating the Once-Obscure German Nonresident Withholding Tax
Podcast: Credit Funds: Withholding Tax on European Investments
Podcast: Cum-Ex Dividend Trade Investigations
Anyone can establish a business in Germany - irrespective of citizenship, nationality, or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
Today, two weeks after the German Federal Parliament (“Bundestag”), the German Federal Council (“Bundesrat”) also passed the 2022 Tax Amendment Act (Jahressteuergesetz 2022)....more
A new report (the Report) published by the German Federal Ministry of Finance (the MOF) suggests that there may be some forthcoming relief for taxpayers impacted by a nearly century-old tax provision which requires...more
Under the new German Tax Relief Act 2022, as of September 1, 2022, employees subject to income tax are entitled to a one-time lump-sum energy price allowance in the amount of €300. The allowance is intended to mitigate the...more
INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more
In this episode of Skadden’s “GILTI Conscience” podcast, partners Nate Carden and David Farhat discuss the German nonresident withholding tax with partner Johannes Frey, in the Frankfurt office, and Ryan Lange and Kerim Keser...more
Even without a German nexus, in cases of a licensing of right registered in Germany an application/disclosure before 30 June 2022 might be necessary. ..According to the German Federal Ministry of Finance (BMF) the...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
This briefing highlights a number of international pay and employee benefits legal issues that carry potentially severe penalties. Each of these issues is well worth a review now to avoid future consequences. International...more
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 gross royalties that are...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
In a decree published November 6, 2020, the German tax authorities confirmed their view that transactions between non-German parties (e.g., between two U.S. companies) are generally taxable in Germany, if this income is...more
Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more
The shock waves from the German authorities’ tax evasion investigation into cum-ex transactions, a complex form of dividend arbitrage, continue to be felt throughout Europe. A large number of UK and European financial...more
As part of our periodic updates, here is an overview of recent developments of relevance to participants in the real estate finance market across certain key jurisdictions in Europe....more
In a recently published decision, the German Federal Tax Court (Bundesfinanzhof, BFH) clarified for the first time that a remuneration for the complete transfer of rights in the context of a “total buy out” against a one-off...more
The German Federal Fiscal Court (BFH) Confirms That Total Buyout Agreements Regarding Copyrights Are Subject to German Withholding Tax - OVERVIEW - Under German tax law, remunerations paid abroad by persons/companies...more
After German tax authorities in the state of Bavaria and others had begun to order some German companies, as part of ongoing audit procedures, to retroactively pay German withholding tax at a rate of 15% on payments to...more
German tax authorities have started utilizing existing income tax rules to impose royalty withholding tax on cross-border digital advertising services. According to news reports, tax authorities in one of the largest German...more
Anyone can establish a business in Germany - irrespective of citizenship, nationality or place of residence. There is no specific investment legislation for foreign entrepreneurs. Any entrepreneur can make his choice from...more
German legislator introduces tax exemption for income resulting from debt waivers in restructuring scenarios with retroactive effect. On 23 November 2018, the German legislator approved legislation regarding tax exemption...more