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.
Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort