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Here you will find all contact details and publications of Dr. Christian Engelen International Tax Law / Transfer Pricing 18.12.2025 | Dr. Christian Engelen, Dr. Nils Linnemann Federal Central Tax Office (BZST) changes practice for relief from withholding tax on US income US investments have traditionally been of great importance to the German economy. The return on investment of US corporations is significantly influenced by the tax… International Tax Law / Transfer Pricing 22.01.2021 | Prof. Dr. Sven-Eric Bärsch, Dr. Christian Engelen Revised Administrative Guidance on Transfer Pricing and Tax Audits Transfer pricing and the documentation of arm’s-length transfer prices are closely scrutinized and often disputed in tax audits. Germany has had administrative guidance… International Tax Law / Transfer Pricing 28.10.2019 | Prof. Dr. Sven-Eric Bärsch, Dr. Christian Engelen Anti-treaty shopping rule: German tax court lowers substance requirements The German anti-treaty shopping rule under Sec. 50d(3) of the German Income Tax Act (ITA) is designed to prevent abusive relief from withholding tax on dividends and… International Tax Law / Transfer Pricing 17.10.2019 | Prof. Dr. Sven-Eric Bärsch, Dr. Christian Engelen What companies should know about the implementation of new EU mandatory reporting rules (DAC6) in Germany On 25 May 2018 the EU Council published a directive (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018L0822) amending Directive 2011/16/EU on the… International Tax Law / Transfer Pricing 04.02.2019 | Dr. Christian Engelen New Mandatory Reporting of Cross-Border Tax Arrangements As of 25 May 2018 the EU Council has published directives amending Directive 2011/16/EU regarding the automatic exchange of information. The amendment refers to the… International Tax Law / Transfer Pricing 21.02.2018 | Prof. Dr. Sven-Eric Bärsch, Dr. Christian Engelen German tax court decides on arms length interest payments for intercompany loans In recent years, transfer pricing case law has attracted increasing attention across Europe, where courts have ruled on cases dealing with intercompany loans. Local…
