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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, Jasmin Steinhart 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… 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… International Tax Law / Transfer Pricing | Tax Law | Corporate and Group Tax Law 23.02.2024 | Prof. Dr. Sven-Eric Bärsch, Dr. Daniel Keuper M.Sc. German tax authorities specify requirements for permanent establishments Due to their function as a tax nexus, the existence ("whether") of international permanent establishments (“PEs”) is increasingly becoming a reason for tax disputes with…
