Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / tax-structuring-memo-withholding-vat.docx
tax-structuring-memo-withholding-vat.docx
Parties
Harkness LLP
Lumos Analytics Inc
Meridian Data Solutions GmbH
Pryce Advisory LLC
Meridian GmbH
Germany Inc
Roles Lumos Analytics Inc
Pacific Registered Agents LLC
Dates
March 15, 2024
April 1, 2024
March 31, 2029
December 31, 2023
June 1, 2006
December 31, 2025
Amounts
$30,000,000
$4,500,000
$5,400,000
$6,300,000
$6,900,000
$187.4
€312
$1,125,000
$56,250
$4.5
Obligations
3 EStG, the payor must withhold tax at a rate of 15% (plus the 5
Under Article 12 of the Treaty, royalties arising in a Contracting State (Germany) and beneficially owned by a resident of the other Contracting State (the United States) shall be taxable only in the United States
To claim the benefits of the Treaty, the following conditions must be satisfied: (a) U
Lumos must be a "resident" of the United States for purposes of the Treaty
Lumos must be the "beneficial owner" of the income received from Meridian
(b) Lumos's invoices to Meridian GmbH must include certain mandatory information: (i) a clear statement that the reverse charge applies (e