23.11.2023 Advocate General: Refusal of option for full income tax asse ... The Cologne Tax Court is of the opinion that the preclusion of German employees resident in Switzerland for full assessment of German income tax is contrary to EU law and had referred the case to the ECJ for a preliminary ruling. In his Opinion, the Advocate General considers that the German regulation contravenes the Agreement for the Free Movement of Persons between the EU and Switzerland. Categories: European Court of JusticeKeywords: free movement of persons, tax assessment
30.10.2022 No option for full income tax assessment for German citizen ... According to the Cologne Tax Court, the preclusion of German employees resident in Switzerland for full assessment of German income tax is contrary to EU law. The court has referred the case to the European Court of Justice (ECJ) for a preliminary ruling with respect to the Agreement for the Free Movement of Persons between the EU and Switzerland. Categories: Tax CourtKeywords: employment income, free movement of pers ...
28.02.2019 Expatriate exit taxation contravenes the Agreement for Free ... The ECJ held that the expatriate exit tax rule under Section 6 Foreign Tax Act contravened the principle of non-discrimination contained in the Agreement for the Free Movement of Persons between the EU and Switzerland. Categories: European Court of JusticeKeywords: exit tax, tax deferral, free movement of ...
30.04.2015 Continued German tax liability under DTT does not conflict w ... An ECJ advocate general has suggested the court rule that there is no conflict between the discrimination prohibition of the EU/Swiss free movement agreement and the Swiss/German double tax treaty provision for the continued German taxation of German source income of a former resident. Categories: From EuropeKeywords: Switzerland, discrimination, free moveme ...