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Tax Deductibility of License Fee Payments under German Tax Law – The License Barrier Rule Pursuant to Sec. 4j of the German Income Tax Act

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4. Legal Consequences

4.1. Income Tax Burden of Licensor

If the prerequisites stipulated by Sec. 4j(1) ITA are met, the license payments are…

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3.4. Interposed Cases and Sub-Licensing Agreements
4.2. Exception: OECD Nexus Approach