Taxpayers that are not residents of Germany may not be fully taxed on their German-source income. However, there recently have been situations when the tax authorities imposed tax liability on payments made to non-resident internet portal operators for online advertising (that is, withholding tax obligations were imposed with regard to such payments).
Because there were conflicting treatments of such payments, the German Federal Ministry of Finance (BMF) issued guidance basically providing that payments received by non-resident platform operators and internet service providers for the placement of online advertising on internet pages were not subject to tax withholding (or a “tax deduction” as referred to by some tax professionals).
Read a May 2019 report [PDF 341 KB] prepared by the KPMG member firm in Germany
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