On 2 June 2017, the German Federal Council (upper house of parliament - Bundesrat) passed the laws to restrict the deduction of related party royalty expenses and to increase disclosure requirements for offshore (shell) companies.
Royalty Deduction Restrictions and Other Changes
The law restricting royalty deductions limits the deduction of royalty payments to related parties made after 31 December 2017 if the income is taxed at a rate of less than 25% as a result of the benefits of an IP …