Johannes Suttner, Author at Kluwer International Tax Blog

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

Extraterritorial Taxation of IP Transactions in Germany – A Critical Analysis of the Statutory Requirements in the Context of the New Circular Letter of the German Federal Ministry of Finance Dated February 11, 2021

Alexander Haller, Johannes Suttner, Katrin Guggenberger (WTS Munich, Germany)/May 3, 2021May 4, 2021 /Leave a comment

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

Foreign-to-foreign licensing subject to withholding tax in Germany?

Alexander Haller, Johannes Suttner, Leon Zimmermann (WTS Munich, Germany)/January 25, 2021March 9, 2021 /Leave a comment

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…