In three landmark rulings, the Federal Fiscal Court has decided that permanent establishments are not employers within the meaning of double taxation agreements. The rulings have significant implications for (domestic and foreign) payroll tax obligations in the case of international employee assignments.
In the article “BFH on the employer status of permanent establishments” by Dr. Gero Burwitz and Jonathan Storz, published in Neue Zeitschrift für Gesellschaftsrecht, you can find out what income tax obligations apply to groups with cross-border structures, what tax risks they face, and what structuring options companies should now consider.
