Taxation of legal entities - EURO

UEFA European Championship Final Tournament 2024, Legal Information

Content Type
UEFA Guidelines

German business profits are subject to two taxes:

  • Corporation tax – at a rate of 15.825%

  • Trade tax – at a rate set by the municipality where the company has a domestic PE. Rates range from around 8% to around 20%.

German resident companies are subject to tax in Germany on their worldwide income. Most double tax treaties allow profits attributable to non-German PEs to be exempt from tax in Germany.

Non-resident companies are subject to German corporate tax on trading profits attributable to a German PE, while royalties and dividends are subject to withholding tax at source.

Germany consistently applies the definition of permanent establishment given in Article 5 of the OECD Model Tax Convention. To provide some indicative guidance, this would generally mean that activities of a preparatory or auxiliary nature linked to the staging of an event such as EURO 2024 performed by a non-resident entity in Germany for a period of less than six months would not lead to the creation of a German PE (though careful analysis of expected activities in Germany and the applicable double tax treaty should be performed by each UEFA partner).