In the May 2002 issue of International Tax Review (page 58), we reported on a decision by the Cologne Tax Court interpreting language contained in article 23(3) of the former tax treaty between Germany and Canada as a subject-to-tax clause and giving this clause precedence over provisions in the treaty by which items of income "shall be taxable only" in Canada. On appeal, the Federal Tax Court (FTC) has now overruled both the lower court decision and its own 1992 holding on point (judgment of December 17 2003, IR 14/02).
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
Law firms that pay close attention to their client relationships are more likely to win repeat work, according to a survey of nearly 29,000 in-house counsel
Luis Coronado suggests companies should embrace technology to assist with TP data reporting, as the ‘big four’ firm unveils a TP survey of over 1,000 professionals
KPMG Netherlands’ former head of assurance also received a permanent bar and $150,000 fine; in other news, asset management firm BlackRock lost a $13.5bn UK tax appeal