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German Tax Authority Challenging Treaty Benefit Claims on Dividends Paid by Disregarded Entities to U.S. Parent Companies

|Treaty Development|Germany-United States
Germany-United States

According to recent reports, the German Federal Central Tax Office (BZSt) has recently adopted a restrictive administrative practice regarding withholding tax on dividend distributions paid by German companies (GmbHs) to U.S. parent companies. They are now frequently denying withholding tax relief on dividends paid by a German GmbH to its U.S. parent if the GmbH is treated as a disregarded enti…