Adrian ȚAGA, Romania’s National Tax Agency, discusses the April 7 European Court of Justice ruling in case C-333/20 Berlin Chemie A. Menarini that addresses whether in the underlying case the German shareholder has a permanent establishment for VAT purposes in the country of its Romanian subsidiary.
New York City Economist Dr. J. Harold McClure analyzes the French Court of Appeal’s January 25 ruling in favor of the multinational in a somewhat involved intercompany financing pricing issue in a decision in case number 20VE00792; SAS Electricité de France International (SAS EDFI) is France’s largest electricity provider and owns the UK affiliate EDF Energy UK Ltd (EDFE).
Dragos Dancau, Ericsson, discusses the European Court of Justice’s March 10 publication of the opinion of Advocate General Collins in C-538/20 Finanzamt B v W AG; the case leaves questions the German referring court raised on how previous cases should be interpreted and shows the maze in analyzing the deduction of the final losses of a nonresident PE within the EU.
Oliver Treidler and Tom-Eric Kunz, TP&C, analyze the current transfer pricing landscape in Germany, following the plethora of updates to regulations and administrative principles in 2020 and 2021, which has led to considerable uncertainty regarding tax audits as well as an increased compliance burden.
Thomas Schänzle, Christian Port, Florian Gimmler, Justus Eisenbeiß, Christian Witthus, Kevin Prashil Brusa and Rabea Lingier, Baker & McKenzie, analyze the far-reaching, practical implications of the amendments to the anti-treaty-shopping provision and transfer pricing rules in Germany’s Withholding Tax Relief Modernization Act (AbzStEntModG), which took effect June 9 . . .
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