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International Tax Law / Transfer Pricing | Global Mobility | Private Clients 23.12.2025 | Michal Fabian Kühn, Stephan Linseisen LL.M., Max Dietrich Federal Tax Court finally clarifies how payouts from US pension plans are taxed in Germany Payments from US pension plans, including the 401(k) plan type, are not treated as a capital gain. Instead, they are recognized as pension payments and are subject to the… 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 | Global Mobility | Private Clients | Foundations & NPO 20.11.2025 | Michal Fabian Kühn, Dr. Michael Tischendorf Is Attribution Taxation on the brink of reform? A draft bill looks at revising Sec. 15 of the German Foreign Tax Act (of 18 November 2025) Section 15 of the German Foreign Tax Act (Außensteuergesetz, “AStG”) provides that, under certain conditions, the current income of foreign foundations and trusts is… International Tax Law / Transfer Pricing 11.07.2025 | Dr. Christian Hick The German Federal Tax Court decided that the Dutch 30%-rule does not result in actual non-taxation of salary payments In the appeal decision of 10 April 2025 (VI R 29/22) published on 3 July 2025, Germany’s Federal Tax Court (the Bundesfinanzhof) addressed the requirements for the actual… Indirect Taxes | International Tax Law / Transfer Pricing 07.07.2025 | Dr. Andreas Erdbrügger, Leonard Joost LL.M. New transfer pricing and value-added tax developments Within international company groups, a large number of goods and services are supplied on a daily basis. The focus is usually on transfer prices for income tax purposes.… International Tax Law / Transfer Pricing 05.05.2025 | Dr. Christian Hick BFH: A permanent establishment is not an employer under tax convention law In its decisions of 12 December 2024 (VI R 25/22, VI R 26/22 and VI R 27/22) published on 17 April 2025, the Federal Tax Court (Bundesfinanzhof – BFH) dealt with the… International Tax Law / Transfer Pricing 02.05.2025 | Michal Fabian Kühn, Dr. Michael Tischendorf, Dr. Michael Schwindt Attribution taxation: Federal Tax Court grants relief for settlors and beneficiaries of foreign trusts and foundations Settlors and beneficiaries of foreign trusts and foundations are exposed to a wide range of tax risks. Sometimes, settlors and beneficiaries in Germany can face a tax… International Tax Law / Transfer Pricing 13.12.2024 | Prof. Dr. Sven-Eric Bärsch, Hendrik N. Schmidt M.Sc. Germany Publishes Newly Updated Administrative Guidance on Transfer Pricing On December 12, 2024, the German Federal Ministry of Finance (BMF) has issued newly updated Administrative Guidance governing Transfer Pricing (Administrative Principles… Tax Law | International Tax Law / Transfer Pricing 02.12.2024 | Michal Fabian Kühn, Stephan Linseisen LL.M. Annual Tax Act 2024: Foreign retirement plan reforms Germany’s Annual Tax Act 2024 (Jahressteuergesetz) brings tweaks to the country’s Income Tax Act (Einkommensteuergesetz). Due to adjustments to Sec. 22 no. 5 sentence 2…
