-
Tightening of the interest barrier
In addition to an extension of the interest expenses subject to this rule, the exemptions have also been modified, which is likely to lead to a (further) restriction of the deduction of interest expenses for many companies.
-
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.