German IP: Change is coming
It appears the Section 49 provision, imposing withholding taxes on IP registered in Germany, will soon be abolished.
At the meeting of the U.S. Council for International Business and OECD, a representative from the Ministry of Finance stated that this change should happen shortly.
The context behind this welcome change appears to be from other countries analogizing the current position as having hallmarks of a digital service tax. Additionally, the absence of the withholding tax should, technically and/or procedurally, should ease a transition into the Pillar 1 and 2 plans.
Strategizing Multinational Tax Risks 