Permanent Establishment: German Ministry of Finance Clarifies Key Criteria
The German Federal Ministry of Finance (BMF) has issued important administrative guidance on the definition of a permanent establishment and the circumstances...
Archive for the category ‘International Tax Planning’
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Germany–Russia Double Taxation Agreement: Suspension Effective January 1, 2027
Tax implications for German subsidiaries with Russian parent companies In a letter dated January 7, 2026, the German Federal Ministry of Finance (BMF)...
S Corporations & LLCs with German Subsidiaries: Taxation of Profits
Participation exemption for dividend distributions despite U.S. pass-through tax treatment? So-called hybrid U.S. entity structures are widely used in...
Properly Categorizing Carried Interest Between Germany And The U.S.
Carried interest payments are highly significant, particularly in international private equity and venture capital investments. As soon as fund structures are...
International Family Foundations And Trusts: Reform of The German Foreign Tax Act
Family foundations and trusts are an established tool in international wealth and succession planning. However, for founders or beneficiaries residing in...
Permanent Establishment Reloaded: What The German Federal Ministry of Finance Plans for 2026
Holistic approach instead of case-by-case analysis: What the new BMF draft changes regarding permanent establishments A home office in Munich, a holding...
Moving to the United Arab Emirates
Caution regarding foreign companies and management in the UAE Many wealthy individuals are drawn to Dubai or Abu Dhabi, among other places, to benefit from the...
Workation And Co.: Is Working from Abroad Becoming a Tax Trap?
Permanent establishment through cross-border work The world of work has changed, and with it the rules of taxation. On November 19, 2025, the OECD published a...
Foreign Family Foundations from A German Perspective: Flexibility vs. Risk
In times of globally networked asset structures, wealthy families and entrepreneurs are increasingly turning to foundation solutions abroad to secure family...
Tax Benefits When Moving to Spain: Making The Most of Beckham Law
For years, many German-speaking entrepreneurs, investors, and wealthy individuals have been considering moving to Spain. Regions such as Mallorca, Ibiza, and...
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