German Ministry of Finance Issues Guidance on Royalty Payment Deduction Restriction
The German Ministry of Finance has published two guidance letters concerning the restriction on the deductibility of royalty payments that are subject to taxation under a preferential tax regime. The restriction limits the deduction of royalty payments to related parties made after 31 December 2017 if the income is taxed at a low rate of less than 25% as a result of the benefits of a preferenti…
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