Companies must use German PEs for business restructuring before law change

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

Companies must use German PEs for business restructuring before law change

Joe Dalton
April 10 2012

Germany is amending its transfer pricing laws so transactions between permanent establishments (PEs) will be treated the same as those between subsidiaries, leading to exit taxes on the transfer of functions.

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

NewsRegulationTransfer PricingGermanyJurisdictions
JD
Joe Dalton
Contact
Joe Dalton worked at ITR between 2011 and 2013
more across site & shared bottom lb ros

More from across our site

Direct Tax
UK Cost Transparency Troubles (1).png
UK tax adviser ‘shocked’ at in-house costs criticism
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
Tom Baker, July 04 2025
Direct Tax
1024px-Donald_Trump_(53911666084).jpg
This week in tax: Donald Trump’s ‘big beautiful’ tax bill narrowly gets through Congress
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
Sam Sholli, July 04 2025
Direct Tax
France business handshake
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
Grocery store
‘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
TP document - compliance.jpg
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
Artificial intelligence
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
US Canada trade
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
Parliament House Canberra
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
Global digital
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
Gift this article