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Germany Targets IP Tax Havens, Law Against Harmful Tax Practices Planned

Germany - January 10 2017 The German Ministry of Finance recently published a draft "act against harmful tax practices in connection with the licensing of intellectual property…

Dr. Cornelia Wiendl

German Tax Circular Has Wide-Ranging Implications for IP Transactions and M&A

European Union, Germany - December 2 2020 On November 6, 2020, the German Ministry of Finance (BMF) issued a circular (the “Circular”) interpreting a long-ignored provision of German tax law…

Michael Lebovitz, Dr. Ulrich Worm

Limited German Tax Deductibility of Low-Taxed License Payments Made to Related US Entities

Germany, USA - July 19 2018 Pursuant to the “license barrier” rule in Sec. 4j German Income Tax Act, newly introduced as of 1 January 2018, arm’s length business expenses of a…

Susan Günther

The German Section 49 Saga Continues - Important Developments in Germany’s Extraterritorial Taxation of IP Transactions

Germany - July 7 2022 On June 29, 2022, the German Ministry of Finance (MoF) issued an important circular (the “2022 Circular”) in the ongoing saga of the application of…

Michael Lebovitz, Kai Yan

Cayman Islands Added to EU Blacklist

Cayman Islands, European Union - February 26 2020 On February 18, 2020, EU finance ministers updated the EU Blacklist, adding four jurisdictions—the Cayman Islands, Palau, Panama and Seychelles…

Astrid Pieron, Benjamin Homo, Jason S. Bazar