Executive summary

On 27 January 2022, the German Ministry of Finance (MoF) published new guidance relating to the German royalty deduction limitation rule dated 5 January 2022 and 6 January 2022. The German royalty deduction limitation rule (Sec. 4j Income Tax Act) partially or wholly disallows the deduction of royalty payments preferentially taxed, directly or indirectly, at the recipient level un…