Suchergebnisse für: `royalties` (961 gefunden)

1. 14. August 2013

   Import value of DVDs includes estimated royalties payable by ...

   The Supreme Tax Court has held that the import value of film DVDs shall include an uplift to the purchase price to reflect royalties payable by the subsequent purchasers on their proceeds from hiring or selling the films. This uplift can be estimated.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: DVD, import value, royalties, customs
2. 24. Juni 2014

   Expense deduction from royalty income paid abroad only if ex ...

   The finance ministry has decreed that a royalty debtor may not deduct expenses of the EEA royalty creditor from the gross royalty subject to withholding tax unless the expense was incurred solely in respect of the given licence.

   Kategorien: Official Pronouncements

   Schlagwörter: royalty, licence, licensee
3. 12. Mai 2011

   Trade tax interest add-back not banned by directive?

   An ECJ advocated general has suggested the court rule that the German trade tax interest disallowance is not a "withholding tax" banned by the Interest and Royalties Directive.

   Kategorien: From Europe

   Schlagwörter: interest, thin capitalisation, trade tax ...
4. 21. Juli 2011

   German trade tax restriction on interest deductibility uphel ...

   The ECJ has upheld the German disallowance of one-half of the long-term interest expense for trade tax as not conflicting with the Interest and Royalties Directive.

   Kategorien: From Europe

   Schlagwörter: trade tax, long-term interest, long term ...
5. 05. Januar 2011

   No requalification of royalty income of US partner to busine ...

   The Supreme Tax Court has held that the treaty attribution of the royalty income charged by a US partner is to his US business. Accordingly, it is not taxable in Germany as partnership profits.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: treaty override, Royalty income, requali ...
6. 07. August 2012

   Royalty withholding tax on net income of EU creditor

   The ECJ has held that the withholding tax on a royalty paid to a corporation in another EU country may not be more than the corporation tax rate applied to the income less the directly related costs.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: withholding tax, royalty
7. 23. November 2011

   EU royalty payments to be taxed net

   The Supreme Tax Court has held that the withholding tax on royalty payments to licensors in other EU states should be on the net amount after deduction of direct costs.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: EU royalty, royalty, Scorpio
8. 14. März 2017

   Plans to restrict the deduction of royalty expenses to comba ...

   On 25 January 2017 the federal government approved a draft of the Act to Combat Harmful Tax Practices in connection with the Licensing of Rights. The intention is to prevent multinational businesses from transferring their royalty income to countries, which offer such income preferential treatment. Such preferential tax regimes (so-called Licence Boxes, Patent Boxes or IP-Boxes) are considered not to meet the demands of the OECD and G20 BEPS Project. A new provision is to be introduced to the Income Tax Act (ITA) for this purpose; the new provision should be applied to expenses arising after 31 December 2017.

   Kategorien: PwC Reports

   Schlagwörter: royalties, licence box, IP-Boxes, Patent ...
9. 08. Februar 2022

   German Federal Ministry of Finance (MoF) published two circu ...

   On January 27, 2022, the German Federal Ministry of Finance (MoF) published two circulars in relation to the royalty limitation rules.

   Kategorien: Official Pronouncements

   Schlagwörter: royalties, Patent Boxes, royalty limitat ...
10. 25. April 2012

    German trade tax restriction on interest deductibility uphel ...

    The Supreme Tax Court has upheld the German disallowance of one-half of the long-term interest expense for trade tax as not conflicting with the Interest and Royalties Directive and not infringing the German/Dutch tax treaty prohibition on discrimination.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: add-back, Inerest deduction, long-term i ...
11. 16. Juli 2021

    Update: Tax & Legal Newsflash – German IP nexus rules: Minis ...

    The circular dated 11 February 2021 covers royalty payments and capital gains in foreign-to-foreign cases where the German nexus is purely based on a registration of rights in a German public register

    Kategorien: Tax & Legal Newsflash

    Schlagwörter: Steuern / Tax
12. 22. Dezember 2016

    Restriction of tax relief on royalty payments: draft bill re ...

    On 25 January 2017 the German government published a draft bill proposing a restriction of tax relief on royalty payments made to related parties from 2018 onwards.

    Kategorien: PwC Reports

    Schlagwörter: BEPS, Royalty expenses, Harmful Tax Prac ...
13. 27. Dezember 2021

    EU draft directive to end the misuse of shell entities for t ...

    On 22 December 2021 the European Commission presented a draft directive to prevent the abuse of shell companies for tax purposes whereby amending the Anti-Tax Avoidance Directive (ATAD 3). The proposal should ensure that entities in the EU that have no or minimal economic activity are unable to benefit from any tax advantages and do not place any financial burden on taxpayers.

    Kategorien: From Europe

    Schlagwörter: shell entities, shell companies
14. 10. Juli 2012

    Inventor's premium to ex-employee taxable as royalty

    The finance ministry has accepted as a precedent a Supreme Tax Court ruling that a premium paid to a former employee for an invention during his employment should be taxed as a royalty, rather than as employment remuneration, but insists that employers may only apply the principle if they hold an exemption certificate from their local tax office.

    Kategorien: Official Pronouncements

    Schlagwörter: inventor's premium, ex-employee, former ...
15. 05. September 2012

    No withholding tax on payment to Austrian agency for broadca ...

    The Supreme Tax Court has held that a payment to an Austrian agency for the right to broadcast sporting events is not subject to withholding tax as a payment to the athlete(s) appearing.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: athletes, Artist, broadcasting
16. 11. April 2017

    Tax administration issues guidelines on use of group name

    The German Finance Ministry has commented on possible profit adjustments under Sec. 1 Foreign Tax Act with respect to the use of group name and logo between the taxpayer and a related party.

    Kategorien: Official Pronouncements

    Schlagwörter: income adjustment, group name, firm name ...
17. 08. Juli 2025

    Trade tax addback of profit share of US silent partner

    In a most recent judgment, the Supreme Tax Court decided that the trade tax addback of a silent partner's profit share is subject to the free movement of capital which also applies to third countries (here: the USA). The application of the "grandfather“ clause of Art 64 TFEU (ex-Article 57 TEC) is generally not affected by statements made in a letter from a lower tax authority.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: Non-discrimination, silent partner, trad ...
18. 08. Juni 2017

    Bundesrat approves legislation introducing restrictions on t ...

    In its sitting on 2 June 2017 the Bundesrat (the Upper House) approved the Act to Combat Harmful Tax Practices in connection with the Licensing of Rights.

    Kategorien: Legislation

    Schlagwörter: International Tax, Royalty expenses, Pat ...
19. 03. Mai 2012

    New double tax treaty with Luxembourg

    A revised double tax treaty has been signed with Luxembourg reflecting the current version of the OECD model.

    Kategorien: PwC Reports

    Schlagwörter: double tax treaty, Luxembourg, OECD mode ...
20. 03. Mai 2012

    New double tax treaty with the Netherlands

    A revised double tax treaty has been signed with the Netherlands reflecting the current version of the OECD model.

    Kategorien: PwC Reports

    Schlagwörter: double tax treaty, OECD model, Netherlan ...
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