Content area

Abstract

The Cologne Tax Court interpreted language contained in article 23 (3) of the tax treaty between Germany and Canada as a subject-to-tax clause, and gave this clause precedence over provisions in the treaty by which items of income "shall be taxable only" in Canada. The relation of this clause to language in the treaty is highly controversial and of considerable practical significance.

Details

Title
Germany: Scope of subject-to-tax clauses in German tax treaties
Author
Sauter, Thomas
Pages
58-59
Publication year
2002
Publication date
May 2002
Publisher
Euromoney Institutional Investor PLC
ISSN
09587594
Source type
Scholarly Journal
Language of publication
English
ProQuest document ID
230187391
Copyright
Copyright Euromoney Institutional Investor PLC May 2002