Germany: Treatment of interest payments from a German partnership to its foreign partners – the increased risk of double taxation

November 12 2013

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).

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

Indirect Tax

External advisers didn’t know North American e-invoicing requirements: in-house leader

A technology provider had to be educated on technical requirements by Joseph Ribkoff’s IT team, Aline Berbari of Joseph Ribkoff said

Sam Sholli, June 24 2026

Indirect Tax

External providers offer accountability ‘if things go wrong’: in-house leader on ViDA

But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard

Tom Baker, June 23 2026

Direct Tax

UK tax gap increases to £59.2bn

Non-compliance from small businesses continues to account for most of the gap, HM Revenue and Customs revealed

Tom Baker, June 23 2026

Direct Tax

Tom McDanell on tackling growth with patience

The new managing director of R&D tax relief consultancy ForrestBrown tells ITR about his priorities for the business, where he’s focusing his time and what makes tax cool

June 22 2026

Direct Tax

A taxing week: KPMG’s shabby scandal response can be improved by learning PwC lessons

PwC Australia’s response to its tax leaks scandal could give KPMG a useful case study, but so far there’s little sign of positive lessons learned

Sam Sholli, June 19 2026

Direct Tax

This week in tax: Judge denies ex-US Supreme Court advocate retrial bid

Tom Goldstein’s attempt to overturn his tax conviction was shot down; in other news, Deloitte promoted several tax partners in Italy

Tom Baker, June 19 2026

Direct Tax

Exclusive: Andersen Global bolsters India presence through JMP Advisors agreement

The tax advisory firm becomes the latest member of the Andersen Global network, which has more than 50,000 professionals worldwide

Sam Sholli, June 18 2026

Transfer Pricing

OECD’s new Chapter VII: documentation matters, but transaction understanding comes first

A revised Chapter VII signals a move away from mechanical TP approaches, stressing transaction understanding, functional analysis and context-driven documentation requirements

Bruno Osterloh, June 18 2026

Direct Tax

HMRC’s GfC13: why governance is paramount for taxpayers and advisers

HMRC’s growing focus on evidencing tax decisions is shifting attention from technical accuracy to governance, requiring businesses to demonstrate how positions were reached and documented

Rebecca Arthur, June 17 2026

Direct Tax

KPMG Australia hit with ban on new contracts amid scandal

Australia’s Department of Finance will also commission an independent review of KPMG’s governance, culture, ethics and integrity frameworks, it has revealed

Sam Sholli, June 16 2026