German Federal Tax Court Decides on PE Definition and Keeps Traditional Interpretation

Journal
Ditz, X.; Quilitzsch, C.; Dapprich, T.N.
Germany
International Transfer Pricing Journal 2023 (Volume 30), No. 2
FormatPDF
EUR
40
| USD
45
(VAT excl.)

The German Federal Tax Court specified and clarified the German definition of a permanent establishment in its decision of 23 March 2022. As a large number of tax consequences are linked to this, this article presents the decision and places it in the preceding legal situation.