Germany Tax News
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Revised Commentary on Article 7 of OECD Model released
ECJ
Federal Cabinet adopts Draft Bill on corporate tax reform
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Final Report on Improving the Resolution of Tax Treaty Disputes
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
Federal Ministry of Finance issues Draft Bill on corporate tax reform
Report on Attribution of Profits to PEs released
Federal Ministry of Finances clarifies application of CFC rules
Treaty between Germany and Belgium - Mutual agreement concerning treatment of severance payments
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Annual Tax Act 2007 and Bill on implementation of European company approved by Federal Council
Treaty between Singapore and Germany enters into force
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
Revised proposal on corporate tax reform
German Federal Tax Court holds CFC rules not applicable in cases of administratively limited tax relief in order to comply with low taxation threshold
Federal tax authority publishes guidance on APAs
On 23 August 2006, the Federal Cabinet approved the Annual Tax Act 2007. The newly included Sec. 20(2b) Income Tax Act, which extends the restriction on loss set-offs from tax deferral schemes, shall already apply for the tax year 2006. To become effective, the Bill has to be passed by the Federal Council as well.
Plans to reform corporate taxation – Federal Cabinet agrees on general framework
Proposed reform concerning cross-border mergers – Bill approved
US Senate may hold hearings on new Denmark, Finland, and Germany protocols
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
US
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
Federal Council approves Bill on Tax Changes 2007
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