Other Foreign Rules
Transfer of fixed assets to foreign branches
In Germany, a German head office that transfers fixed assets to a foreign branch is subject to tax on the deemed capital gain on those assets if:
the branch's profits are tax exempt, or
foreign tax on the branch is creditable against German income taxes under an applicable tax treaty between Germany and the country where the branch is situated.
Ref: Income Tax Act (Einkommensteuergesetz), 19 October 2002, BGBl I p 4210, §§ 4(1) No 3, 6(1) No 4
Passive foreign investment companies (PFICs)
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