German Ministry of Finance publishes guidance on German taxation of extraterritorial intellectual property

Executive summary

On 6 November 2020, the German Ministry of Finance (MoF) issued letter guidance concerning the German nonresident taxation of income from rights which are registered in a German public register. The letter briefly states that the registration of intellectual property (IP) rights in a German register is sufficient to trigger nonresident taxation of license or capital gains income derived from such rights, and that it is not required for any of the parties involved to be a German …