Suchergebnisse für: `double-tax-treaty` (129 gefunden)

1. 03. Mai 2012

   New double tax treaty with Luxembourg

   A revised double tax treaty has been signed with Luxembourg reflecting the current version of the OECD model.

   Kategorien: PwC Reports

   Schlagwörter: double tax treaty, Luxembourg, OECD mode ...
2. 03. Mai 2012

   New double tax treaty with the Netherlands

   A revised double tax treaty has been signed with the Netherlands reflecting the current version of the OECD model.

   Kategorien: PwC Reports

   Schlagwörter: double tax treaty, OECD model, Netherlan ...
3. 03. Juni 2019

   Locker can constitute a fixed place of business for double t ...

   The Supreme Tax Court refused to overturn the tax court’s decision to refuse leave to appeal, agreeing with the lower court that a locker can constitute a fixed place of business within the meaning of Article XI Paragraph 1 of the German/British double tax treaty.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: double tax treaty, permanent establishme ...
4. 20. Dezember 2011

   Bank levy double tax treaty with UK

   Germany and the UK have signed a double tax treaty on bank levies for retrospective application to January 1, 2011.

   Kategorien: PwC Reports

   Schlagwörter: bank levies, German levy
5. 05. Januar 2011

   Swiss double tax treaty excludes thin capital rule

   The Supreme Tax Court has held that the thin capital rules in force up to 2007 are in breach of the non-discrimination clause in the Swiss double tax treaty.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: Non-discrimination, thin capital rules, ...
6. 23. November 2011

   Double tax treaty with Liechtenstein

   The government has broken with its standing policy of not signing double tax treaties with tax havens with its signature on an OECD model treaty with Liechtenstein.

   Kategorien: PwC Reports

   Schlagwörter: double tax treaty, Liechtenstein
7. 13. September 2012

   Double Tax Treaty with Austria – civil service pensions

   The German and Austrian finance ministries have agreed to tax civil service pensions paid to widows as though payment continued to be to the original beneficiary.

   Kategorien: Official Pronouncements

   Schlagwörter: double tax treaty, pension, German/Austr ...
8. 09. April 2014

   Old “thin cap” rule breaches non-discrimination clause of do ...

   The Supreme Tax Court has held that the application of the pre-2008 “thin capital” rule to disallow interest on related party finance breaches the discrimination prohibition of double tax treaties.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: interest limitation, thin cat, debt/equi ...
9. 26. August 2024

   Exit tax upon transfer of Germanys right for taxation under ...

   In a case where Germany lost the right to tax the investment in a Spanish corporation the Supreme Tax Court - in contrast to the opinion held by the tax administration - decided that the German exit taxation pursuant to Section 6 para. 1 sentence 1 Foreign Tax Act applies to the year in which the German unlimited income tax liability ends and not at the later point in time when the limited tax liability arises.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: exit tax
10. 31. März 2025

    German-French double tax treaty: Taxation of severance payme ...

    As the state of employment, Germany has the right to tax a severance payment to the extent that the employee has exercised the activity in Germany. According to a decision of the Supreme Tax Court in the case of cross-border situations, the exclusion to tax benefits in kind from the exercise of share options and comparable rights under tax treaty law is based pro rata temporis on the place of employment of the employee during the vesting period (defined as the period in which the employee is entitled to acquire the options).

    Kategorien: Supreme Tax Court cases

    Schlagwörter: stock options, severance payment, income ...
11. 17. Februar 2025

    Allocation of employment income of airline pilot under Doubl ...

    According to a most recent decision of the Supreme Tax Court, the income from employment of a pilot resident in Germany and who is employed in international air traffic by a Swiss-based company is only exempt from German income tax (subject to progression) to the extent that he performs his activity on Swiss soil and in Swiss airspace in accordance with the principle of territoriality.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: airlines, income from employment
12. 28. Oktober 2024

    Taxation of severance payments for cross-border commuters un ...

    In a recent judgment the Supreme Tax Court decided that - according to Article 13 paragraph 1 of the double tax agreement (DTT) with France - Germany has the right to tax the severance pay as a result of the termination of an employment relationship insofar as the compensation relates to the period during which the employee (who was subject to unlimited tax liability at the time) lived and worked in Germany. The taxable amount must be calculated by considering the duration of the domestic residence compared to the term of the employment. The so-called cross-border commuter rule in Article 13 para. 5 of the DTT does not preclude Germany’s right of taxation.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: cross-border commuters, severance paymen ...
13. 17. Mai 2023

    Double tax treaty with Switzerland: New consultation agreeme ...

    The German and Swiss tax authorities have concluded a new consultation agreement regarding the group of persons to whom Article 15 paragraph 4 applies to ensure the uniform application and interpretation of Article 15 paragraph 4 of the double tax agreement between Germany and Switzerland (Federal Ministry of Finance, letter dated 25 April 2023).

    Kategorien: PwC Reports

    Schlagwörter: double tax treaty, mutual agreement
14. 21. Juni 2022

    Tax exemption under a double tax treaty - amendment after as ...

    In a recent ruling, the Münster Tax Court had to decide on the income tax and treaty law treatment of a severance payment received by the plaintiff as a soldier in the British armed forces

    Kategorien: Tax Court

    Schlagwörter: double tax treaty, tax exemption, correc ...
15. 01. Dezember 2021

    Dividend exemption under double tax treaty or abuse of legal ...

    The distribution of profits by a Luxembourg subsidiary (in the legal form of a SARL) to its German parent company (a partnership limited by shares – KGaA) may be an abuse of legal forms where the KGaA provided SARL with a loan and shortly thereafter waived repayment, thereby putting SARL in a position to actually make the profit distribution. Even more when the losses arising from the impairment of the value of SARL because of the distribution are to be used by the shareholders in a tax-effective manner.

    Kategorien: Tax Court

    Schlagwörter: dividend exemption, abuse of legal forms ...
16. 14. Oktober 2024

    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 ...
17. 28. Juni 2011

    Former Yugoslav treaty applies to Kosovo

    Germany and Kosovo have agreed to follow the German/Yugoslav double tax treaty in their mutual tax relations.

    Kategorien: PwC Reports

    Schlagwörter: double tax treaty, Yugoslav, Kosovo
18. 21. Juni 2011

    Former Yugoslav treaty applies to Montenegro

    German and Montenegro have agreed to continued application of the former German/Yugoslav double tax treaty.

    Kategorien: Official Pronouncements

    Schlagwörter: Yugoslav, Montenegro
19. 18. April 2013

    Treaty policy

    The finance ministry has published its model double tax treaty serving as a guideline to negotiators.

    Kategorien: Official Pronouncements

    Schlagwörter: double tax treaty, treaty policy
20. 21. März 2013

    Old corporation tax rate on German branch income of non-EU c ...

    The Supreme Tax Court has held that the corporation tax rate on the permanent establishment income of non-EU foreign companies under the old, pre-2001 system was acceptable under community law and the double tax treaty.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: permanent establishment (PE), branch, im ...
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