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Mnster tax court refers to ECJ treaty-override provision in German Foreign Tax Law re low-taxed passive foreign PE income — Orbitax
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Mnster tax court refers to ECJ treaty-override provision in German Foreign Tax Law re low-taxed passive foreign PE income

|Treaty Development|Germany-Belgium
Germany-Belgium

The local tax court (Finanzgericht) of Mnster recently requested a preliminary ruling from the European Court of Justice (ECJ) regarding the compatibility of a treaty-override provision under the Foreign Tax Law (Auensteuergesetz), which provides for a switch-over from the exemption method to the credit method in respect of low-taxed passive foreign permanent establishment (PE) income, with the ba…

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