Germany Tax News
US Treasury Department announces signing of protocol to US-Germany income tax treaty
11 July 2006
Proposed reform concerning cross-border mergers
11 July 2006
Indian decision on applicable tax rate for down payment for transfer of technical know-how
14 May 2006
Reorganization Act – proposed amendments to facilitate EU cross-border mergers
14 May 2006
Further attempts by Federal Ministry of Finance to clarify thin capitalization rules
9 April 2006
Treaty between Germany and United Arab Emirates to expire
9 April 2006
Central Tax Board rules on treaty characterization of partnership income re Finland-Germany tax treaty
9 April 2006
German state-owned bank not exempt from interest withholding tax
19 February 2006
It has been announced by the German Federal Ministry of Finance that negotiations are ongoing for a new protocol to the income and capital tax treaty of 21 July 1959 between Germany and France. Further details of the treaty will be reported subsequently.
19 February 2006
The Federal Cabinet on 18 January 2006 adopted a draft Bill providing for tax amendments aimed at the furtherance of economic growth and employment (Entwurf eines Gesetzes zur steuerlichen Förderung von Wachstum und Beschäftigung). The most important proposed amendments to the enterprise taxation are summarized below. Unless otherwise indicated, the proposed amendments would apply from tax year 2006.
19 February 2006
German Federal Tax Court reverses its case law denying refund of dividend withholding tax to interposed Netherlands holding companies
9 November 2005
Mnster tax court refers to ECJ treaty-override provision in German Foreign Tax Law re low-taxed passive foreign PE income
16 October 2005
Germany and Iceland initialled a new income and capital tax treaty on 6 July 2005. Once in force, the new treaty will generally replace the Germany-Iceland income and capital tax treaty of 18 March 1971. Further details of the treaty will be reported subsequently
16 October 2005
Ministry of Finance decrees non-applicability of Federal Tax Court decision re cross-border transfer pricing adjustment
21 September 2005
Germany confirmed that negotiations for a new tax treaty with the Philippines are ongoing, although no scheduled negotiation dates have been released. Once signed and in force, the new treaty will replace the Germany-Philippines income and capital tax treaty of 22 July 1983.
3 August 2005
Cyprus and Germany initialled a new tax treaty on 10 June 2005. Once in force, the new treaty will replace the Cyprus-Germany income and capital tax treaty of 9 May 1974. Further details are not yet available.
3 August 2005
As of 29 June 2005 negotiations between Germany and Taiwan regarding the conclusion of a first-time tax treaty are still ongoing. The first round of negotiations was held in December 2003.
3 August 2005
The 1975 treaty on income and capital will be terminated by 1 January 2006 and, according to the information available up to date, not be replaced by a new treaty.
1 May 2005
The new income and capital tax treaty and protocol between Poland and Germany signed on 14 May 2003, entered into force on 19 December 2004. The new treaty generally applies from 1 January 2005.
19 January 2005