25.03.2024 Withholding tax on income of foreign artists performing in G ... In a recent ruling, the Supreme Tax Court has commented on the tax treatment of fees paid to artists with limited tax liability for their performances in Germany. A key criterion for tax deduction at source is the intention to make a profit and the commercial objective of the performances in Germany. Categories: Supreme Tax Court casesKeywords: foreign artist, limited taxpayer
22.03.2019 Unlimited tax liability with dual residency The fact that a taxpayer has both a residence in Germany and a residence abroad does not, according to a ruling by the Supreme Tax Court, preclude the existence if an unlimited tax liability even when the foreign residence constitutes the centre of the taxpayer’s vital interests Categories: Supreme Tax Court casesKeywords: centre of vital interests, limited taxpa ...
23.05.2018 Pensions paid abroad subject to limited tax liability A limited tax liability on payments by the German State pension fund to a resident of Canada is not nullified by the tax treaty. Categories: Supreme Tax Court casesKeywords: pensions, Tax Treaties, limited taxpayer ...
27.10.2017 Disposals of shares by limited taxpayers: no add-back of fic ... The Supreme Tax Court has ruled that where a limited taxpayer has no permanent establishment (branch/permanent representative) located in Germany, the add-back of fictitious business expenses cannot be applied. Categories: Supreme Tax Court casesKeywords: Corporation tax, Share disposal, exempt ...
