Schlagwörter: allocation of taxing rights (3 gefunden)

1. 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 ...
2. 09. April 2021

   Successful constitutional complaint against income correctio ...

   The German Constitutional Court overturned a 2019 judgment of the Supreme Tax Court regarding the erstwhile change in its case law on the issue of the income correction with respect to an unsecured group loan because the tax court failed to submit the facts of the case to the European Court of Justice (ECJ) for final clarification and thus violated the complainant's right to the lawful judge under Article 101(1) of the Constitutional Statute.

   Kategorien: Constitutional Court

   Schlagwörter: allocation of taxing rights, income corr ...
3. 28. Mai 2018

   ECJ decision German CFC regulations to be published on 31 Ma ...

   The publication of the decision of the European Court for Justice (ECJ) in the Hornbach-Baumarkt case is scheduled for 31 May 2018.

   Kategorien: European Court of Justice

   Schlagwörter: freedom of establishment, CFC, allocatio ...