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Nexia Ebner Stolz

International

Limited tax liability applies to royalty payments between non-residents

In a let­ter dated 6 Novem­ber 2020, the Federal Mini­s­try of Finance (BMF) com­men­ted on an inter­pre­ta­tion of Ger­man limi­ted tax lia­bi­lity on roy­alty pay­ments, an issue that has emer­ged as con­tro­ver­sial in the recent past. The BMF’s legal posi­tion may have sig­ni­fi­cant con­se­qu­en­ces for inter­na­tio­nally ope­ra­ting groups of com­pa­nies. The easing of the legal requi­re­ment that had been ori­gi­nally plan­ned no lon­ger appears to be on the cards.

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