Abstract
The author discusses a series of recent German court decisions addressing the issue of whether US S-Corporations must be granted the reduced withholding tax rate of 5% on German-sourced dividends under the Germany-United States Income and Capital Tax Treaty. The final Federal Fiscal Court decision clarifies the interpretation of treaty article 1(7) concerning income derived by and through fiscally transparent persons and is relevant for the application of the treaty to all hybrid entities.
Sign-in/Register to access full text options 
Talk to us
Join us for a 30 min session where you can share your feedback and ask us any queries you have
Schedule a callDisclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.
