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Germany - Germany: Federal Tax Court Closes Loophole in Germany–Luxembourg Tax Treaty

Country:
Germany
Author:
Andreas Perdelwitz
Issue:
European Taxation, 2009 (Volume 49), No 3
Published:
1 March 2009
In its decision of 4 July 2008, the Federal Tax Court (Bundesfinanzhof, BFH) held that the income of a German limited liability company derived from a participation as a typical silent partner of a Luxembourg company is not exempt in Germany in accordance with the Germany–Luxembourg tax treaty. In this note, the author considers the Federal Tax Court’s decision.
 
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