Foreign corporations may freely repatriate
Foreign corporations may freely repatriate their German branch profits, other
forms of permanent establishment income, or profit shares from their
partnership holdings without further taxation.
There is no form of “branch profits tax” or other substitute for a dividend withholding tax. Dividends
repatriated by companies are subject to a dividend withholding tax, which will
be a final burden from the German point of view, unless the recipient of the
dividend is a German tax-resident corporation or natural person.
EU Forecast
euf:ba18e:146/nws-01