The Supreme Tax Court has held that compensation for loss of office is taxable in the state of residence under the German/Swiss tax treaty and not in the state of employment. A mutual agreement between the two revenue authorities to the contrary is not to be applied for lack of an adequate legal basis.
The Supreme Tax Court has held that compensation paid to a German resident employee of a French company for his redundancy is taxable in France by virtue of the particular wording of the employment income article of the double tax treaty.