OrbitaxGerman Exit Tax on Transfer of Assets to EU PE Compatible with EU Law
|Approved Changes|European Union-Germany
The European Court of Justice on 21 May 2015 rendered its ruling in the case Verder LabTec GmbH & Co. KG v. Finanzamt Hilden (Case C‑657/13). The case involved a German limited partnership which transferred IP rights to its Dutch permanent establishment. The transfer triggered an exit tax in Germany on the unrealized gains inherent in the transferred IP rights, which is required to be paid …
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