14.08.2023 Russia suspends DTAs with "unfriendly" states On 8 August 2023, a presidential decree was published, under which the selected provisions of international double tax treaties (DTTs) must be suspended until "the respective foreign states eliminate the violations of legitimate economic and other interests of the Russian Federation." Categories: PwC ReportsKeywords: double tax treaty, Russia
17.05.2023 Double tax treaty with Switzerland: New consultation agreeme ... The German and Swiss tax authorities have concluded a new consultation agreement regarding the group of persons to whom Article 15 paragraph 4 applies to ensure the uniform application and interpretation of Article 15 paragraph 4 of the double tax agreement between Germany and Switzerland (Federal Ministry of Finance, letter dated 25 April 2023). Categories: PwC ReportsKeywords: double tax treaty, mutual agreement
08.07.2022 Finance Committee approves amendments on two double tax agre ... On 6 July 2022 the Finance Committee of the German Bundestag (whose working scope basically coincides with the responsibilities of the Federal Ministry of Finance) approved specific revisions to the double tax treaties with Mauritius and Mexico. Categories: LegislationKeywords: BEPS, double tax treaty, Profit Shifting
21.06.2022 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 Categories: Tax CourtKeywords: double tax treaty, tax exemption, correc ...
06.05.2022 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. Categories: Tax CourtKeywords: double tax treaty, permanent establishme ...
03.06.2019 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. Categories: Supreme Tax Court casesKeywords: double tax treaty, permanent establishme ...
25.05.2018 Federal Finance Ministry circular on the tax treatment of sa ... The Federal Finance Ministry circular of 12 November 2014 on the taxation of salaries for tax treaty purposes has been revised by a committee made up of from both the Federal and the States’ governments. Categories: Official PronouncementsKeywords: double tax treaty, Federal Ministry of F ...
08.06.2017 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. Categories: Official PronouncementsKeywords: OECD, BEPS, double tax treaty, Internati ...
16.02.2016 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. Categories: PwC ReportsKeywords: treaty override, double tax treaty, cons ...
18.04.2013 Treaty policy The finance ministry has published its model double tax treaty serving as a guideline to negotiators. Categories: Official PronouncementsKeywords: double tax treaty, treaty policy
13.09.2012 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. Categories: Official PronouncementsKeywords: double tax treaty, pension, German/Austr ...
03.05.2012 New double tax treaty with Luxembourg A revised double tax treaty has been signed with Luxembourg reflecting the current version of the OECD model. Categories: PwC ReportsKeywords: double tax treaty, Luxembourg, OECD mode ...
03.05.2012 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. Categories: PwC ReportsKeywords: double tax treaty, OECD model, Netherlan ...
26.04.2012 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. Categories: Official PronouncementsKeywords: double tax treaty, pension fund, retirem ...
23.11.2011 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. Categories: PwC ReportsKeywords: double tax treaty, Liechtenstein
28.06.2011 Former Yugoslav treaty applies to Kosovo Germany and Kosovo have agreed to follow the German/Yugoslav double tax treaty in their mutual tax relations. Categories: PwC ReportsKeywords: double tax treaty, Yugoslav, Kosovo
31.03.2011 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. Categories: Supreme Tax Court casesKeywords: double tax treaty, pre-retirement
05.01.2011 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. Categories: Official PronouncementsKeywords: double tax treaty, Intercorporate divide ...
