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).
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The newly launched Tax Responsibility and Transparency Index will assess the ethicality of companies’ tax practices against global standards and regulations
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