12. September 2017 Profit participation rights at fixed rate is interest under ... In a dispute between Germany and Austria on the right of taxation of payments from registered certificates the ECJ held that such interest should be taxed only in the country of residence of the beneficial owner unless such debt-claims explicitly provide the creditor with a participation in the debtor’s profits. Kategorien: European Court of JusticeSchlagwörter: fixed-term debentures, interest, profit ...