OrbitaxMinistry of Finance publishes guidance on application of subject-to-tax, remittance basis and switch-over clauses under tax treaties in respect of a decision of the Federal Financial Court
|Treaty Development|Germany
On 27 August 2013, the Ministry of Finance published guidance in form of an official letter dated 20 July 2013, regarding the application of subject-to-tax, remittance basis and switch-over clauses under tax treaties, taking into account a decision of the Federal Financial Court of 17 October 2007 (I R 96/06).
Subject-to-tax clauses
The guidance differentiates between three types o…
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