The Federal Fiscal Court (Bundesfinanzhof – BFH) has decided that Germany's switchover clause for taxing income from foreign partnerships is incompatible with EU law, even though the European Court of Justice (ECJ) reached the opposite conclusion in the same case, Columbus Container Services v Finanzamt Bielefeld-Innenstadt (C-298/05).
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The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
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