Suchergebnisse für: `double-tax-treaty` (108 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: Luxembourg, OECD model, double tax reaty
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. 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
4. 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: hidden distribution, Non-discrimination, ...
5. 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 ...
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. 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 ...
10. 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 ...
11. 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
12. 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
13. 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: treaty policy, double tax treaty. model ...
14. 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, branch, imputat ...
15. 20. Juli 2011

    Swiss company “delegate” is tax treaty director

    The Supreme Tax Court has held that a German resident “delegate” of the board of a Swiss company is a director within the meaning of the double tax treaty.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: delegate, Swiss company, director
16. 30. April 2015

    Continued German tax liability under DTT does not conflict w ...

    An ECJ advocate general has suggested the court rule that there is no conflict between the discrimination prohibition of the EU/Swiss free movement agreement and the Swiss/German double tax treaty provision for the continued German taxation of German source income of a former resident.

    Kategorien: From Europe

    Schlagwörter: Switzerland, discrimination, free moveme ...
17. 06. August 2014

    DTT France – compensation for loss of employment taxable in ...

    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.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: France, loss of employment, loss of offi ...
18. 07. Oktober 2015

    Post-dissolution profits and losses from foreign P.E. attrib ...

    The Supreme Tax Court has held that the profit from the release of a provision no longer required arising from a foreign permanent establishment long after closure falls under the business profits clause of the relevant double tax treaty and is thus taxable in the foreign country.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: branch, provision no longer required, pe ...
19. 02. Januar 2013

    No transfer pricing adjustment for breaches of formality

    The Supreme Tax Court has rejected a tax office assessment attempt on the basis of a hidden distribution of profits because of a delay in agreeing management charges in writing, saying that the double tax treaty related party provision bases the arm’s length standard on amount, rather than on the reason for, or documentation, of a transaction.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: related party, transfer pricing, managem ...
20. 31. Oktober 2013

    Foreign partner receives business income from the interest o ...

    The Supreme Tax Court has held that a foreign limited partner must accept attribution of the shares in a British distributor company held by the partners to the partnership. In consequence, the interest on a shareholder loan falls to the partnership, where it is requalified as trading income. The interest clause in the double tax treaty with the partner’s home country is inapplicable.

    Kategorien: Supreme Tax Court cases

    Schlagwörter: shareholder loan, partner, interest inco ...
21. Weitere laden