Jan Becker Sebastian Hölscher The Annual Tax Bill 2007 will introduce a switch-over clause into German tax law denying a treaty exemption to German residents if, due to differing legal definitions of income, the other country either does not tax the respective income at all, or only by withholding. The same will apply where the other country does not tax the income because it does not see the recipient as its own tax resident.
September 30 2006