PwC

Tax & Legal

Tax & Legal

Unlimited tax liability with dual residency


The fact that a taxpayer has both a residence in Germany and a residence abroad does not, according to a ruling by the Supreme Tax Court, preclude the existence if an unlimited tax liability even when the foreign residence constitutes the centre of the taxpayer’s vital interests Continue reading

Disposals of shares by limited taxpayers: no add-back of fictitious business expenses without domestic branch


The Supreme Tax Court has ruled that where a limited taxpayer has no permanent establishment (branch/permanent representative) located in Germany, the add-back of fictitious business expenses cannot be applied. Continue reading