Germany - Classification of Foreign Entities for German Tax Purposes
- C. Kahlenberg
- European Taxation, 2014 (Volume 54), No 4
- 24 February 2014
The author provides an overview of the classification process for foreign legal entities in Germany for taxation purposes. The criteria that are determinative are outlined and the overall significance of individual criteria in the classification process is analysed. The extent to which criteria considered significant by the tax authorities have been sanctioned by the law is addressed, as well as whether such criteria are also applicable to foreign legal entities other than US LLCs.