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Dr. Christian Port

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Christian Port is a member of Baker McKenzie's International Tax Group based in Frankfurt. He is highly experienced in providing tax advice to German and foreign multinational companies in complex national and international corporate tax matters, with a strong focus on deal-related tax structuring and group reorganizations. Christian joined Baker McKenzie’s Frankfurt office in 2009 and was elected partner in 2015. He studied law in Trier and London, was admitted to the German bar in 2009 and qualified as certified German tax advisor in 2011. Additionally, he also served as a research assistant at the Institute for Technical and Environmental Law at the University of Trier where he received his Ph.D. in law in 2011. Christian has published numerous tax articles during his professional career and is a frequent speaker at national and international tax conferences.
In Tax

Germany: New tax audit focus – Application of Royalty Barrier Rule to Foreign-Derived Intangible Income (FDII)

by , and 5 Mins Read

Does your group have a German subsidiary or a German branch that pays royalties to a related party abroad under an intra-group license agreement? If so, a recent development in the German tax landscape could significantly affect you: The German Royalty Barrier Rule (RBR, Section 4j of the German Income Tax Act, (ITA)) is increasingly becoming relevant in German tax audits. Importantly, the German Tax Authorities (GTA) recently began expanding their scrutiny beyond traditional Patent/IP Box regimes.