New rules complicate Germany anti-treaty shopping law

June 30 2012

Germany’s anti-treaty shopping rules are among the most stringent in the world, explain Markus Schümmer and Markus Buchner of Ernst & Young. This was true for the rules that applied up to 2011, and it is still the case for the revised rules that apply from 2012 onward.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Pillar two is revising global tax competition with a 15% minimum tax rate

A taxing week: Pillar two will prosper despite US side-by-side arrangement

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos

Paul Monaghan, February 27 2026

Direct Tax

This week in tax: PwC commences legal battle with boutique consultancy founded by ex-COO

The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week

Sam Sholli, February 27 2026

Direct Tax

Washington DC Capitol view on cloudy sky background

Ex-US Supreme Court advocate convicted on 12 counts in tax trial

Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff

Sam Sholli, February 26 2026

Transfer Pricing

Suited figure pointing to audit among various hexagonal icons

TP documentation in a fragmented world: how to limit audit triggers

Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions

Daniel Moalusi, February 26 2026

Direct Tax

‘Tax at breaking point’: Thomson Reuters’ AI tech hits one million users

The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR

Sam Sholli, February 24 2026

Direct Tax

Deloitte unveils €20bn EMEA combination

The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth

Tom Baker, February 24 2026

Indirect Tax

The IBS and why it changes everything in Brazil’s consumption tax system

Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty

Wesley Fragas, February 24 2026

Direct Tax

A&M Tax launches dedicated pillar two, TP team in Saudi Arabia

The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering

Tom Baker, February 23 2026

Direct Tax

India and France sign updated tax treaty in ‘significant development’

The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits

Sam Sholli, February 23 2026

Indirect Tax

‘Refunds likely to be a mess’: US Supreme Court strikes down Trump’s tariffs

The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled

Sam Sholli, February 20 2026