International Tax Law / Transfer Pricing

International Tax Law / Transfer Pricing
23.10.2024 | Michal Fabian Kühn, Dr. Florian Lindermann
New exit tax rules for investment shares
The Annual Tax Act 2024 shall extend how an asset’s increase in value is taxed under Sec. 6 of Germany’s Foreign Tax Act (the Außensteuergesetz). One of its key measures…
International Tax Law / Transfer Pricing
01.07.2024 | Prof. Dr. Sven-Eric Bärsch, Dr. Sven Kluge
New Guidance on Germany’s APA Programme for Transfer Pricing Purposes
The German tax authorities (GTA) have updated their administrative explanations on Advance Pricing Agreements (APAs) providing guidance on how they interpret the APA…
International Tax Law / Transfer Pricing
18.04.2024 | Michal Fabian Kühn, Stephan Linseisen LL.M.
New Rules on Taxing Foreign Currency Gains in Private Assets
Investing private wealth, savings or assets in foreign currencies can make good economic sense. In practice, it has become an established means of diversifying…
International Tax Law / Transfer Pricing
26.03.2024 | Prof. Dr. Sven-Eric Bärsch
2024 Growth Opportunities Act: New Transfer Pricing Rules for Financial Transactions
In November 2023, the Bundestag passed the Growth Opportunities Act aimed at strengthening Germany’s competitiveness as a business location.  The Bundesrat then approved…
International Tax Law / Transfer Pricing
25.03.2024 | Prof. Dr. Sven-Eric Bärsch, Anna Nußbaum, Hendrik N. Schmidt M.Sc.
International case law on transfer pricing in December 2023
Transfer pricing is increasingly becoming the focus of domestic and foreign tax authorities and tax courts, particularly in the light of tax audits. It is therefore worth…
Person mit Koffer am Flughafen als Symbol für den Wegzug nach Portugal
Global Mobility | International Tax Law / Transfer Pricing | Corporate and Group Tax Law
13.03.2024 | Prof. Dr. Sven-Eric Bärsch, Dr. Daniel Keuper M.Sc.
New administrative guidance on the place of effective management
The increased mobility of individuals can also have far-reaching consequences for companies. The place of effective management (Sec. 10 General Tax Code, referred to as…
International Tax Law / Transfer Pricing
08.03.2024 | Michal Fabian Kühn, Barbara Sarrazin
Update United Kingdom (UK): Contemplated changes to the ‘non dom’ regime
In the UK’s Spring Budget on 6 March 2024, the Chancellor of the Exchequer of the current Conservative government, Jeremy Hunt, proposed a new tax system  that would…
International Tax Law / Transfer Pricing | Tax Law | Corporate and Group Tax Law
23.02.2024 | Dr. Carsten Quilitzsch LL.M., Dr. Gabriel Hörnicke LL.M., Dr. Stefanie Rötting LL.M.
Position of the German tax authorities on Service PEs
A permanent establishment (“PE”) is a key factor in establishing a limited tax liability in Germany. Also, German trade tax depends on the existence of a PE in Germany.…
International Tax Law / Transfer Pricing | Tax Law | Corporate and Group Tax Law
23.02.2024 | Dr. Christoph Klein, Yannick Barbu LL.M., Licencié en droit
New administrative guidance on „home office“ permanent establishments
Have we escaped the daily commute? Remote working has significantly increased in recent years, accelerated by the recent pandemic. More and more companies have been…
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