OrbitaxTreaty between Germany and United States – German Federal Financial Court rules on non-deductibility of losses from US (non-EU/EEA) PE
|Treaty Development|Germany-United States
In a recently published decision of 11 March 2008, the German Federal Financial Court (Bundesfinanzhof) held that losses from permanent establishments in the US (i.e. non-EU/EEA) are not deductible for tax purposes in Germany. Details of the decision are summarized below.
(a) Facts. In the tax year 1999, the plaintiff, a German limited liability company, particip…
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