German draft law for modernisation of withholding taxes relief and new anti-abuse measures

Sven-Eric Bärsch 03 Dec 2020

On 20 November 2020, the Federal Ministry of Finance issued the draft for a law on the modernisation of the relief from withholding taxes

On 20 November 2020, the Federal Ministry of Finance issued the draft for a law on the modernisation of the relief from withholding taxes.

Changes have been proposed for the following tax rules in particular:

procedure to obtain relief from German withholding taxes (“WHT”) on the basis of income tax treaties or EU tax provisions;
specific anti-abuse rule against treaty shopping;
limitation of German limited (non-resident) taxation of income from IP being (merely) registered in a domestic register.

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