In December 2004 the German tax authorities issued a directive addressing a judgment rendered by Germany's highest tax court in January 2003. In this decision, the Federal Tax Court held that a foreign corporation having its registered office in the US and its principal place of management in Germany could qualify as the parent entity (first-tier entity) in a group of companies consolidated for corporation tax purposes, even though applicable law for the year in dispute required the corporation to have both its registered office and its principal place of management in Germany (double nexus requirement).
February 01 2005