Limited tax liability and tax withholding in case of indefin ...
The transfer of know-how by a foreign creditor for an unlimited period may lead to limited income tax liability in Germany by way of tax withholding. The fact that the know-how must be used domestically in order to trigger German withholding tax does, according to the Supreme Tax Court, not require that the know-how also had the specified scope, substance and quality to fulfill the purposes pursued in the domestic market.
Kategorien: Supreme Tax Court cases
Schlagwörter: withholding tax, limited tax liability