Asset Allocation to Bank Permanent Establishments – The German Perspective
Journal
Country
Germany
Published Date
Issue
International Transfer Pricing Journal 2019 (Volume 26), No. 5
Document
There are special regulations covering the determination of profits and, thus, the taxation of bank permanent establishments in Germany. Mainly, these rules relate to the determination of the key entrepreneurial risk-taking function and, consequently, the allocation of assets. Given that the rules are largely pro-fiscal and not always in conformity with the arm’s length principle, double taxation may result.