21. Oktober 2024 No tax exemption of foreign branch income in case of treaty ... The Supreme Tax Court decided that the “switch-over" provision in the respective tax treaties with Russia and Romania, which changes the exemption method to the credit method, was to be applied by observing the activity requirements set in Section 8 (1) of the German Foreign Tax Act. Kategorien: Supreme Tax Court casesSchlagwörter: foreign tax credit, switch over provisio ...
22. Mai 2012 Constitutional Court to rule on treaty override The Supreme Tax Court has laid its doubts on the constitutional propriety of the treaty override switch over provision in respect of employment income not taxed in a foreign state with the taxing right under a treaty. Kategorien: Supreme Tax Court casesSchlagwörter: treaty override, employment income, swit ...
