Germany - Global Executives as Permanent Representatives in Germany – Tax Risks for Foreign Businesses
- C. Heinz; S. Leidel
- European Taxation, 2019 (Volume 59), No 10
- 11 September 2019
In this note, the authors discuss the potential risk of non-resident enterprises being subject to “limited tax liability” in Germany due to executive bodies being resident in or conducting business in Germany, a recent decision of the German Federal Fiscal Court in this regard and its implications in practice.