Schlagwörter: fixed place of business (4 gefunden)

1. 18. August 2023

   Permanent establishment and fixed business facility for serv ...

   The requirements for a permanent establishment pursuant to Section 12 sentence 1 German Fiscal Code, which are also characteristic for the concept of a permanent establishment under the double tax treaty with the United Kingdom, are met if the person providing the service (here: an aircraft mechanic/engineer) is given only restricted use of site-related business facilities (here: locker and safe deposit box in common rooms on the airport premises) in the course of his services (here: maintenance work on aircraft). This was decided by the Supreme Tax Court in a most recent judgment.

   Kategorien: Supreme Tax Court cases

   Schlagwörter: permanent establishment (PE), supply of ...
2. 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 Court

   Schlagwörter: double tax treaty, permanent establishme ...
3. 08. Juli 2021

   VAT: No permanent establishment in case of property rental

   The European Court of Justice (ECJ) ruled that the reverse charge is applicable to the leasing of real property located in Austria because the Jersey based lessor, in lieu of own local staff to perform services relating to the letting, does not have a permanent establishment (fixed place of business) in Austria.

   Kategorien: European Court of Justice

   Schlagwörter: reverse charge, permanent establishment ...
4. 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 ...