A new decision by the Bundesfinanzhof (BFH) significantly increases the risk of permanent establishments for taxpayers. The BFH has now decided that even a small locker is sufficient to establish a permanent establishment in Germany. We explain which principles of the BFH established and which effects result for practice.
1st event of the establishment
The acceptance of a permanent establishment in accordance with § 12 sentence 1 AO constitutes a
This article does not replace tax or legal advice in an individual case. Facts, current law, jurisdiction, documentation and implementation remain decisive.