German-Swiss double tax treaty: Right for taxation during la ...
In a most recent judgment, the Supreme Tax Court decided that in a case where an employee working in both Germany and Switzerland until the termination of the employment relationship and thereafter is irrevocably released from his duties with continued payment of his salary, the income from employment pursuant to Art. 15 para. 1 sentence 1 of the double tax agreement between Germany and Switzerland is subject to tax only in Germany as the country of residence.
Kategorien: Supreme Tax Court cases
Schlagwörter: employment income, allocation of taxing ...