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  • Article

    VAT: EU Publishes Consultation Report On Recast Of Sixth Directive

    The EU has published its report on the results of the 2003 public consultation on the recast of the Sixth Directive. Editorial suggestions have been taken into account; calls for changes in substance have not.
    GermanyTax
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    Protocol Amending FYR Macedonia – Germany Tax Treaty Ratified By Germany

    At the end of March 2017, the German Federal Council has approved the protocol amending the tax treaty concluded with FYR Macedonia.
    GermanyTax
    Eurofast
    Eurofast
  • Article

    Is it Feasible for Employees Assigned to Germany to Remain on the Payroll of the Parent Company?

    Is it Feasible for Employees Assigned to Germany to Remain on the Payroll of the Parent Company? PwC Frequently Asked Question.
    GermanyStrategy
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    Germany Enters Into New Tax Treaty With The Netherlands

    Germany and the Netherlands signed a new double taxation treaty on 12 April 2012.
    GermanyTax
    De Brauw Blackstone Westbroek
    De Brauw Blackstone Westbroek
  • Article

    Tax Simplification: Finance Ministry Reports Progress On Streamlining Procedures

    The finance ministry has published a progress report on its efforts to date to simplify tax procedures with online assessment and collection.
    GermanyFinance and Banking
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    EU - Amended Parent/Subsidiary Directive Promulgated

    The amendment of December 22, 2003 to the EU Parent/Subsidiary Directive was officially published in the Official Journal on January 13, 2004. It enters into force 20 days later, that is on February 2, 2004. Member states have until December 31, 2004 to change their statutes, regulations and other provisions to comply.
    GermanyTax
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    Germany Agrees With UK And Switzerland On Arbitration Procedures To Resolve Double Taxation

    Due to an increased number of long-lasting Mutual Agreement Procedures not solved within an appropriate period of time yet, the need for a (mandatory and terminating) arbitration procedure in international double taxation cases becomes more and more obvious and relevant.
    GermanyTax
    Oppenhoff
    Oppenhoff
  • Article

    Supreme Court - Write Down of Loan to Shareholder is not a Hidden Distribution

    The Supreme Ttax Court decided that the write-down of a loan to a shareholder does not constitute a hidden distribution as the anticipated loss of the loan asset has not yet been realised.
    GermanyTax
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    Transfer pricing: EU proposes Arbitration Code of Conduct

    The European Commission has proposed a Code of Conduct for all procedures under the Arbitration Convention with the object of avoiding double taxation on intra-community trade.
    GermanyTax
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    German Legislator Adopts MLI Application Act

    On 16 May 2024 the Ger­man Bun­des­tag ad­op­ted the draft of an ap­pli­ca­tion law for the BEPS-MLI, which was pre­sen­ted by the Ger­man go­vern­ment on 7 Fe­bru­ary 2024. On 14 June 2024...
    GermanyTax
    RSM Ebner Stolz
    RSM Ebner Stolz
  • Article

    No Subject To Tax Clause In The Canadian Double Tax Treaty - Supreme Tax Court

    The Supreme Tax Court has held that the Canadian double tax treaty of 1981 - in force up to 2000 - does not make treaty exemption dependent upon actual taxation in the other state.
    GermanyInternational Law
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    Interest On Withholding Tax Refunds In Cases Of Incorrect Application Of A Double Tax Treaty

    The Cologne Fiscal Court has ruled that taxpayers may be entitled to interest on delayed tax refunds under EU law, even when the initial refusal was based on incorrect application of a double taxation agreement rather than direct EU law provisions. This decision extends beyond previous rulings that limited interest claims to cases involving EU directives, potentially opening new avenues for taxpayers facing prolonged withholding tax refund delays.
    GermanyTax
    A&O Shearman
    A&O Shearman
  • Article

    Potential Tax Consequences Of Brexit From A German Perspective

    On 23 June, the UK is holding a referendum to decide whether it should leave or remain in the European Union.
    European UnionTax
    Reed Smith (Worldwide)
    Reed Smith (Worldwide)
  • Article

    Do I Have To Report Income From Abroad On My German Tax Return?

    German tax residents must report worldwide income on their tax returns, including rental income from foreign properties and investment earnings from abroad.
    GermanyTax
    GGI | Global Alliance
    GGI | Global Alliance
  • Article

    Bundesrat Rejects Tax Bills

    GermanyInternational Law
    PricewaterhouseCoopers
    PricewaterhouseCoopers
  • Article

    German TP Update: Amended Guidance On International Mutual Agreement And Arbitration Procedures

    On 24 September 2025, the German Federal Ministry of Finance (Bundesfinanzministerium) published an updated version of the guidance on International Mutual Agreement and Arbitration Procedures...
    GermanyTax
    Alvarez & Marsal
    Alvarez & Marsal
  • Article

    Permanent Establishments Often Arise Earlier—And More Easily—Than Companies Expect

    The establishment of a PE remains a key tax issue for companies operating internationally, as it is decisive for the allocation of taxable profits between different jurisdictions...
    GermanyTax
    Alvarez & Marsal
    Alvarez & Marsal
  • Article

    ECJ Decision Offers Foreign Investors Chances To Claim Refunds Of German Dividend Withholding Taxes

    Foreign investors should be advised that there is no guidance at which tax office they may claim a withholding tax refund based on the ECJ decision.
    European UnionTax
    Cleary Gottlieb Steen & Hamilton
    Cleary Gottlieb Steen & Hamilton
  • Article

    Germany And The Netherlands Sign Protocol To Amend The Income Tax Treaty (2012)

    On 24 March 2021, Germany and the Netherlands signed an amending protocol (Protocol) to amend the Germany – Netherlands Income Tax Treaty (2012) (Treaty) as amended by the 2016 protocol...
    European UnionTax
    Loyens & Loeff
    Loyens & Loeff
  • Article

    Konzernklausel des § 6a GrEStG nach Generalanwalt beim EuGH keine verbotene Beihilfe

    Mithilfe der Vorschrift des § 6a GrEStG können grundstückbesitzende Unternehmen und Konzerne Umstrukturierungen durchführen ...
    GermanyTax
    Arnold & Porter
    Arnold & Porter

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