On 19 February 2020, the German Ministry of Finance (MoF) issued guidance concerning harmful preferential regimes in connection with the German royalty deduction limitation rule. The decree identifies and lists harmful preferential tax regimes in a non-exhaustive list, which should fall under the German royalty deduction limitation rule beginning with the 2018 assessment period. The status of the United States (US) Foreign Derived Intangible Income (FDII) deduction is, however, still under review.The German royalty deduction limitation rule (Section 4j of the Income Tax Code) partially disallows the deduction of royalty payments made to recipients in jurisdictions, which are subject to...