Extraterritorial taxation of foreign taxpayers - light at the end of the tunnel?
Recently, the German Ministry of Finance published its proposal for a very welcome change of law.

For almost 100 years, German tax law included a regulation that states that non-residents are subject to limited German taxation on the renting out or sale of rights registered in a German book or register, without any further nexus of any of the parties involved being necessary. For almost 100 years as well, this rule was ignored by many. After the German Ministry of Finance (“MoF”) stirred-up the German tax world in November 2020 by stating that it considers the regulation to apply even when no further nexus with Germany exists, a recently proposed change in legislation may bring some light to the end of the tunnel.

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