German withholding tax on royalty payments between non-German parties - German tax authorities confirm position on withholding obligation and set out procedural guidelines for compliance
By EsqSocial Corporation 24/02/21
On February 11, 2021, the German Federal Ministry of Finance (GFMF) published a decree (the Decree), confirming their position that German withholding tax (at a rate of 15.825%) is due and payable on gross royalties that are payable or that have been paid to a non-German tax resident recipient, even if: ..The licensee is not tax resident in Germany, and ..The only nexus to Germany is that the intellectual property (IP) rights underlying the royalties are entered in a German public register....
By: Eversheds Sutherland (US) LLP