Germany - Anti-Treaty Shopping Rules: Section 50d-3 of the Income Tax Act
- C. Jochimsen; E. Schiffer
- European Taxation, 2014 (Volume 54), No 11
- 15 October 2014
In this note, the authors discuss recent changes to the German anti-treaty shopping provision and provide guidance on how it should be applied. In addition, the note touches on the potential breaches of EU law with regard to the rule.