Germany - Tax Treaty Interpretation in Germany: Utilizing the OECD’s New Approach to the Qualification of Income
- A. Cloer; F. Sixdorf
- European Taxation, 2017 (Volume 57), No 7
- 22 June 2017
The authors, in this note, present the decision of the Lower Fiscal Court of Berlin-Brandenburg in Case 15 K 1093/10 regarding the qualification of income for the purposes of applying tax treaties, including a discussion of its implications on tax treaty interpretation in Germany.