Recent Federal Fiscal Court Decisions on Permanent Establishments

This note provides an update on recent German case law regarding requirements for permanent establishments (PEs) in outbound structures and the profit allocation to an existing PE in an inbound structure. The first case offers valuable guidance on new work concepts, the second tackles a tax avoidance scheme and the third concerns the Authorized OECD Approach.

Publication Details

Journal
European Taxation
Published
2025-10-13
DOI
https://doi.org/10.59403/3cr4r04
Primary Topic
Taxation and Legal Issues
Type
article
Field-Weighted Citation Impact
0.00
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article

Recent Federal Fiscal Court Decisions on Permanent Establishments

European Taxation
Taxation and Legal Issues
article

Recent Federal Fiscal Court Decisions on Permanent Establishments

article en

Abstract

This note provides an update on recent German case law regarding requirements for permanent establishments (PEs) in outbound structures and the profit allocation to an existing PE in an inbound structure. The first case offers valuable guidance on new work concepts, the second tackles a tax avoidance scheme and the third concerns the Authorized OECD Approach.

European TaxationVol. 65(11)
Openalex Percentile: Top 34%
Taxation and Legal Issues
DOISourceOpenAlex
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Recent Federal Fiscal Court Decisions on Permanent Establishments · European Taxation (2025) | TGRS Research Map | TGRS