Germany MOF Announces Amendments to Guidance on Taxation of Employment Income Under DTAs

The German Ministry of Finance Dec. 19 posted online BMF Letter No. COO.7005.100.4.12075924, announcing amendments to guidance on the tax treatment of employment income under specified DTAs. Topics covered include: 1) revised rules requiring employers to certify wage and payroll costs passed on to receiving companies under the arm’s-length principle, with such certification serving as presumptive evidence for employee taxation; 2) clarification on DTA allocation of wages paid during revocable or irrevocable leave of absence, including determining deemed workdays under the Income Tax Act; 3) updated examples on right to tax, for cross-border assignments with companies in Spain and Austria; ...