Tax authority interpretative letter on revised German anti-treaty shopping regulations

January 2012

Overview

A foreign company that receives specific German-source income that is subject to German withholding tax (e.g., dividends, royalty or specific interest payments) may be entitled to relief under the European Union ("EU") Parent-Subsidiary Directive, the Interest and Royalty Directive, or any applicable double tax treaty or domestic tax law. In order to claim German withholding tax relief, the foreign company must document its compliance with the German anti-treaty shopping regulations.

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