19. March 2016

Draft circular on apportionment of profits

The German Federal Ministry of Finance published on 18 March 2016 a draft cirular on the distribution and apportionment of profits between a head office and a permanent establishment. This draft circular explains in detail (152 pages) with many examples how profits shall be allocated between e.g. a foreign head office and a German domestic permanent establishment.

The draft circular will now be reviewed by different parties until 13 May 2016 and shall be published in its final Version in autumn 2016.