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 CourtSchlagwörter: double tax treaty, tax exemption, correc ...
06. Mai 2022 Swiss/German tax treaty: permanent establishment of taxi bus ... The Tax Court of Baden-Württemberg has ruled that premises in a Swiss taxi radio control centre may constitute a permanent establishment and, as a result, the resultant commercial income may be tax-exempt in Germany. Kategorien: Tax CourtSchlagwörter: double tax treaty, permanen establishmen ...
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 casesSchlagwörter: double tax treaty, permanent establishme ...
08. Juni 2017 Multilateral Convention to counter aggressive tax avoidance ... On 7 June 2017 Germany together with the representatives of over 60 countries signed the multilateral convention, which should transpose the main recommendations of the G20/OECD Project against Base Erosion and Profit Shifting (BEPS Project) into existing bilateral tax treaties. Kategorien: Official PronouncementsSchlagwörter: OECD, BEPS, double tax treaty, Internati ...
16. Februar 2016 Treaty override constitutional The Constitutional Court has held the treaty override provisions of the Income Tax Act making treaty exemption dependent upon proof of taxation or explicit exemption in the other state do not breach the formal provisions of the constitution if they took effect after enactment of the treaty. Kategorien: PwC ReportsSchlagwörter: treaty override, double tax treaty, cons ...
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 PronouncementsSchlagwörter: double tax treaty, pension, German/Austr ...
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 ReportsSchlagwörter: double tax treaty, OECD model, Netherlan ...
26. April 2012 US treaty pension funds include those legally held by others The German and US authorities have agreed to treat employee retirement savings schemes and investment trusts holding pension fund assets as pension funds for the tax treaty exemption of dividend income. Kategorien: Official PronouncementsSchlagwörter: double tax treaty, pension fund, retirem ...
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 ReportsSchlagwörter: double tax treaty, Liechtenstein
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 ReportsSchlagwörter: double tax treaty, Yugoslav, Kosovo
31. März 2011 Pre-retirement pay taxable in country of employment The Supreme Tax Court has held that the pre-retirement pay of an employee with no further duties remained taxable in Germany as employment income despite his move to France. Kategorien: Supreme Tax Court casesSchlagwörter: double tax treaty, pre-retirement
05. Januar 2011 Intercorporate dividends from Norway confirmed as tax-free The finance ministry has confirmed its interpretation of the Norwegian DTT to the effect that dividends received by a German company on a holding of 25% or more are free of German taxation. Kategorien: Official PronouncementsSchlagwörter: double tax treaty, Intercorporate divide ...
