Tax & Legal

A taxpayer who emigrated to the U.K. and who exercised his right under U.K. tax law to pay tax on income not earned in the U.K. on a "remittance basis" is caught by the preferential taxation regime of Sec. 2 (2) No. 2 Foreign Tax Act and subject to extended limited tax liability in Germany.

The Supreme Tax Court has held that the treaty protection from extended tax liability for those moving to Switzerland for employment reasons applies to existing, as well as to new, employments.