Investor Presentaiton
ETT/ORIP: German Extraterritorial Tax Regimes ETT/ORIP: 德国域外税收制度
Background 背景
ATA
Extraterritorial Taxation ("ETT") and Offshore Receipts in regard to Intangible Property ("ORIP") is the name given to a tax levied by
a jurisdiction that applies to transactions involving intangible property ("IP") where:
• Neither direct party to the transaction is tax resident in that jurisdiction;
Neither non-resident entity has a local permanent establishment, an avoided permanent establishment under domestic
law, or any other physical presence; and
• The transaction is not executed in that jurisdiction.
This taxing right is typically exercised as a result of: (i) the IP being registered in that jurisdiction; and / or (ii) the IP being used
or exploited in that jurisdiction.
ETT and ORIP can be distinguished as follows:
•
"ETT" applying to transfers of intangibles
"ORIP" applying to payments or accruals for the use of intangibles
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