Tax & Legal

On 10 November 2023, the Bundestag passed the draft bill submitted by the German government on the EU directive on global minimum taxation. The vote was based on a recommendation by the Finance Committee.

Section 50d (9) Income Tax Act (ITA) excludes a tax exemption in Germany under a double tax treaty where, inter alia, the income is not taxed in the other treaty state.

The European Commission has drafted a proposed amendment to the Parent/Subsidiary Directive in the interests of closing perceived loopholes.