The German tax legislator made only a few substantial changes to the tax rules relevant for international business during 2017, the notable exception being the introduction of a new rule that will limit the deductibility of royalty payments made to recipients benefiting from a non-nexus intellectual property (IP) regime, which will apply from 2018 (see March issue of the International Tax Review magazine). In addition, the German courts issued some decisions that will require the legislator to introduce new rules, such as the replacement of the restructuring relief previously granted under an administrative practice based on a circular (see April issue of the International Tax Review magazine) and new change-in-ownership rules (discussed below). Most other changes to the tax code addressed procedural issues, such as increased notification requirements for certain business relationships with third countries and certain reliefs, by increasing the thresholds that allow simplified approaches to depreciation/amortisation, documentation, etc.
December 14 2017
