Administrative obligations, Germany, IP, Residence, Royalties, Tax Treaties

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1. Introduction To be able to compete successfully in international markets, companies need to turn their R&D results fast and effectively into marketable products. Thus, besides the development (enhancement, maintenance, exploitation) of IP, its protection is of essential importance for companies. In order to ensure maximum legal protection, companies oftentimes formally register their IP assets…

Germany, Withholding Taxes

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Introduction Let’s assume the following situation: ParCo is the parent company of a multinational group with its residence in Switzerland and engaged in the automotive business. It developed an innovative battery technology. Due to the high density of competition and rivalry, ParCo is interested in having its innovative technology protected through a patent. For this…

OECD, Transfer Pricing

(WTS Munich, Germany) and (Tax Policy Center of the University of Lausanne, Switzerland)/ /Leave a comment

Introduction The financial crisis had made multinational enterprises (MNE) look inward for funding options, as external sources of capital were not readily available. Among various intra group-financing possibilities, cash pooling among group members is undoubtedly one of the most important tools to facilitate cash management. Even though tax authorities recognize the commercial rationale of such…