This content is from: Sponsored Germany: Entitlement of a US S-Corporation to benefits under the Germany-US tax treaty Oliver Rosenberg, partner at Linklaters in Dusseldorf, summarises a June decision of the Federal Tax Court (FTC) which clarifies the interpretation of Article 1 paragraph 7 and Article 2 paragraph 10 of the Germany/US... By ITR Correspondent November 27 2013
This content is from: Global Cyprus and Luxembourg fail compliance tests on information exchange, says OECD forum Four jurisdictions have received the thumbs-down from their peers in new compliance ratings issued by the OECD's Global Forum on Transparency and Exchange of Information for Tax Purposes. By Ralph Cunningham November 22 2013
This content is from: Germany The two-step approach to permanent establishment profit attribution in Germany Xaver Ditz and Carsten Quilitzsch, of Flick Gocke Schaumburg, explain the two-step approach to PE profit attribution in Germany November 20 2013
This content is from: Germany Germany: Treatment of interest payments from a German partnership to its foreign partne... 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 r... By ITR Correspondent November 12 2013
This content is from: Germany Germany: Adjustment of VAT clauses in contracts for the purchase of immovable property In its circular of October 23 2013, the Federal Ministry of Finance made statements regarding the effectiveness of VAT clauses in contracts for the purchase of immovable property, reports Oliver Zugmaier of küffner ma... November 06 2013
This content is from: Germany MoFo takes Hogan Lovells team; launches in Berlin Morrison & Foerster is launching an office in Berlin, taking nine partners from Hogan Lovells in the city. November 06 2013
This content is from: Germany Germany’s new rules on profit allocation to insurance PEs Ulf Andresen and Jobst Wilmanns of PwC in Frankfurt, explain how Germany’s new profit allocation rules for insurance permanent establishments (PE) potentially discriminate against foreign insurers. November 01 2013
This content is from: Global Cross-border services in tax treaties: crossing the PE border Developing countries often impose withholding tax on payments for certain offshore services. Companies should be aware of where in the world this occurs and the potential protection under tax treaties so they can plan... November 01 2013
This content is from: Sponsored Germany: No real estate transfer tax charge on indirect partial transfer of partnership... November 01 2013
This content is from: Sponsored Americas Tax Awards 2013 The eighth Americas Tax Awards in New York on September 26 was the biggest ceremony to date and also saw the introduction of the new deal awards. By Ralph Cunningham November 01 2013
