BMF announces the release of the German Intergovernmental Agreement for implementing FATCA
On Friday, 31 May 2013, the German Ministry of Finance, Bundesfinanzministerium (BMF), announced the release of the FATCA Intergovernmental Agreement between the Federal Republic of Germany and the United States (German-U.S. IGA) for implementing the broad ranging provisions of the Foreign Account Tax Compliance Act (“FATCA”). The BMF had issued a news release on 21
Germany – New legislation on taxation of portfolio dividends and introduction of refund procedure – impact on Fokus Bank claims
Background In October 2011 (case C-284/09) the CJEU held that the German taxation of portfolio dividends paid to non-resident shareholders was not in line with the free movement of capital (see NA 2011-013). The judgment left Germany the choice between rendering all portfolio dividends (i.e. those paid to residents and non-residents) chargeable to corporation tax
