Oliver Rosenberg, partner at Linklaters in Dusseldorf, discusses the treatment of interest payments from a German partnership to its foreign partners, including why there is an increased risk of double taxation as a result of the new section 50d paragraph 10 of the German Income Tax Act (ITA).
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The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year