The German Bundestag (lower house of parliament) has announced the adoption of the draft laws to restrict the deduction of related party royalty expenses and to increase disclosure requirements for offshore (shell) companies.
The draft law restricting royalty deductions would limit the deduction of royalty payments to related parties if the income is taxed at a rate of less than 25% as a result of the benefits of an IP regime not in compliance with the nexus approach developed as part of B…