author_ey
EY

Share This Article

German Federal Central Tax Office publishes new fact sheet on eligibility for relief under anti-treaty shopping rule

20 March 2025

|

Tax Alerts, Information Reporting, Natio...

|

Germany

The German Federal Central Tax Office (FCTO) has published a new fact sheet regarding the eligibility for an exemption or refund of withholding tax (WHT) under the German anti-treaty shopping rule.Although the fact sheet is not legally binding, it provides taxpayers with important guidance on the FCTO's approach to assessing relief eligibility under this rule.Taxpayers should consider the FCTO's view and review existing structures potentially affected.  Executive summaryOn 17 March 2025, the German Federal Central Tax Office (FCTO) published an update to the fact sheet on the eligibility for an exemption or refund of withholding tax (WHT), applicable to dividends...