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

Direct Tax

French Finance Act 2025: Major tax reform for management packages

New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer

Bruno Knadjian , July 03 2025

Transfer Pricing

‘TP litigation here to stay’: experts dissect South Africa ruling

The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR

Sam Sholli, July 02 2025

Indirect Tax

This month in indirect tax: compliance the top challenge for indirect tax, Thomson Reuters finds

Indirect tax professionals now rate compliance as a bigger obstacle than technology and automation; in other news, Italy approved a VAT cut on art sales

Sam Sholli, July 02 2025

Direct Tax

AI in tax: what’s the direction of travel?

AI-powered tax agents are likely to be the next big development in tax technology, says Russell Gammon of Tax Systems

Russell Gammon, July 01 2025

Direct Tax

Lewin Higgins-Green -- FTI Consulting.jpg

Five minutes with…Lewin Higgins-Green, FTI Consulting

FTI Consulting’s EMEA head of employment tax and reward tells ITR about celebrating diversity in the profession, his love of musicals, and what makes tax cool

July 01 2025

Direct Tax

Canada to scrap DST in bid to resume US trade negotiations

Canadian Prime Minister Mark Carney and US President Donald Trump have agreed that the countries will look to conclude a deal by July 21, 2025

Sam Sholli, June 30 2025

Direct Tax

PwC Australia’s government contract ban should be extended, senators say

The firm’s lack of transparency regarding its tax leaks scandal should see the ban extended beyond June 30, senators Deborah O’Neill and Barbara Pocock tell ITR

Tom Ravlic, June 30 2025

Transfer Pricing

DSTs as digital infrastructure: the tax challenges of emerging markets

Despite posing significant administrative hurdles, digital services taxes remain ‘the best way forward’ for emerging economies, says Neil Kelley, COO of Ascoria

Neil Kelley, June 27 2025

Direct Tax

Pillar two taxes won’t apply to US companies: US Treasury secretary

A ‘joint understanding’ among G7 countries that ‘defends American interests’ is set to be announced, Scott Bessent claimed

Sam Sholli, June 27 2025

Direct Tax

This week in tax: PwC Australia’s tax function generates A$475m amid tumbling 2024 profits

The ‘big four’ firm’s inaugural annual report unveiled a sharp drop in profits for 2024; in other news, Baker McKenzie and Perkins Coie expanded their US tax benches

Sam Sholli, June 27 2025