International tax law
Ruling on withholding tax reduction for S corporations under the Germany-US tax treaty
Cologne Fiscal Court has held that section 50d(1) sentence 11 of the German Income Tax Act [Einkommensteuergesetz – EStG] has merely procedural character. The judgment con-tributes significantly towards eliminating legal uncertainty and has set limits on the tax authori-ties’ pro-taxation stance. Here are the details.