According to a German tax provision dating back to 1925 (Sec. 49 (1) No. 2 lit. f EStG), the mere fact that IP owned by foreigners is either exploited in a German permanent establishment or registered in a German register could trigger non-resident taxation in Germany, even if there is no further nexus in Germany (e.g. none of the affected parties – payer and payee – are German tax residents).