Germany MOF Posts Guidance on Principles for Applying Tax Haven Defense Act

The German Ministry of Finance April 27 posted BMF Letter No. COO.7005.100.2.14703408, announcing amendments to the guidance on principles for applying the Tax Haven Defense Act. Topics covered include: 1) the expanded guidance on when registered bonds are considered comparable to bearer bonds for purposes of the deduction prohibition and withholding tax; 2) that insurance and reinsurance payments are outside the scope of withholding tax, with application of the deduction prohibition to insurance and reinsurance premiums subject to exceptions; and 3) that the enhanced cooperation and documentation obligations for dealings with non-cooperative tax jurisdictions are limited to cases where specified ...