Investor Presentaiton
Brexit 英国脱欧
Summary of tax implications ¾¾ÓNE
•
There are no measures in the Free Trade Agreement between the EU and the United Kingdom to replace the
effects of the Interest and Royalties and Parent-Subsidiary Directives.
.
For tax purposes the United Kingdom will be treated as a third country.
•
•
The double tax treaty between Germany and the United Kingdom from 2010 will be applicable instead of EU
Directives (e.g. parent subsidiary directive or interest and royalty directive).
Under the double tax treaty Germany and the United Kingdom there is a 5% withholding tax right (in case
shareholding above 10%) for dividends. Under the EU parent subsidiary directive there was a 0% applicable.
•
For royalties and interest in general there should be also no withholding tax right according to double tax treaty
Germany and the United Kingdom.
Germany's Ministry of Finance (MOF) published a protocol on 14 January 2021 signed with the UK that will amend the existing Germany-UK tax treaty, as well as a
joint declaration with the UK, both dated 12 January 2021. The protocol will introduce additional anti-abuse provisions into the existing Germany-UK tax treaty that
are similar to provisions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), and the joint
declaration announces negotiations beginning in 2021 for further amendments to the treaty. To enter into force, the protocol must be ratified by both Germany
and the UK and the instruments of ratification will need to be exchanged.
© 2021. For information, contact Deloitte China.
18View entire presentation