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Germany Publishes Competent Authority Agreement Signed with the Netherlands on Double Taxation Relief for Limited Partnerships

31 January 2020

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Treaty Development

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Germany-Netherlands

The German Ministry of Finance published on 23 January 2020 a competent authority agreement signed with the Netherlands on 4 December 2019. The agreement concerns double taxation relief in cases where there is differing treatment by the two countries of a German limited partnership, i.e., the partnership is treated as transparent by Germany and as non-transparent by the Netherlands. The agreement includes rules for the Netherlands to provide, in certain cases, a deemed credit for the elimination of double taxation.