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Justus Eisenbeiss LL.M. (Tax Law), ADIT

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Justus Eisenbeiss is a senior associate and a member of Baker McKenzie’s Tax Practice Group in Frankfurt. Justus has several years of experience in providing tax advice to German and foreign multinational companies on domestic and international corporate tax issues. Prior to joining Baker McKenzie in July 2021 Justus worked in the International Tax Team of PricewaterhouseCoopers Frankfurt.
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Germany: New tax audit focus – Application of Royalty Barrier Rule to Foreign-Derived Intangible Income (FDII)

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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.