Recent Federal Fiscal Court Decisions on Permanent Establishments
Journal
Country
Germany
Published Date
Issue
European Taxation 2025 (Volume 65), No. 11
Document
This note provides an update on recent German case law regarding requirements for permanent establishments (PEs) in outbound structures and the profit allocation to an existing PE in an inbound structure. The first case offers valuable guidance on new work concepts, the second tackles a tax avoidance scheme and the third concerns the Authorized OECD Approach.