German Withholding Tax on Distributions Made to Luxembourg Companies

CJEU Deems German Anti-Abuse Rule Set Forth in Paragraph 50d(3) of the EStG an Infringement   Executive Summary One of the most unfortunate German tax legislations was deemed an infringement by the Court of Justice of the European Union (CJEU) on December 20, 2017: Paragraph 50d(3) of the German Income Tax Act (Einkommensteuergesetz, EStG) pertaining to the …

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