Wednesday, 1 March 2017

German draft bill would restrict deductibility of related-party royalties

The German Federal Cabinet on January 25, 2017, agreed on a draft bill from the German Ministry of Finance that would restrict the tax deductibility of related-party royalty payments, under certain conditions. The German government is focused on situations in which the royalty income is taxed as part of a special patent box regime that does not meet the Organisation for Economic Cooperation and Development’s (OECD’s) 'nexus' approach.

If the draft bill is enacted, the rule is expected to apply to royalty expenses incurred after December 31, 2017.

Source & more info: PwC