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Germany: Permanent Establishments Not Considered Employers Under Tax Treaties

Summary by Taxand
Germany’s Federal Tax Court has recently ruled that foreign permanent establishments are not considered employers under tax treaty law, as they lack legal independence. This means German parent companies must withhold wage tax on salaries for days worked in Germany, even for short visits by employees of foreign branches.
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Taxand broke the news in on Friday, May 9, 2025.
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