Germany - An Assessment of the Draft Rule Limiting the Deduction of Royalties
- B. Heidecke; R. Holst
- International Transfer Pricing Journal, 2017 (Volume 24), No 3
- 20 April 2017
On 25 January 2017, a draft bill was published of a rule limiting the deduction of royalty payments to foreign related parties. The intention of the draft bill is to disadvantage the use of such IP box regimes that are not in compliance with the OECD’s modified nexus approach. The draft bill provides guidance under which conditions the deduction of royalty payments is limited.