Abstract

This article explores two recent judgements of the Federal Tax Court in which the court reaffirmed the limits on exit taxation in cases where the applicable income tax treaty does not prevent the German tax authorities from executing their right to tax income that originated in Germany even though such income – at a later point in time – is only realized in a tax-exempt foreign permanent establishment or by a person that is no longer subject to either resident taxation or taxation at source in Germany.

Talk to us

Join us for a 30 min session where you can share your feedback and ask us any queries you have

Schedule a call

Disclaimer: All third-party content on this website/platform is and will remain the property of their respective owners and is provided on "as is" basis without any warranties, express or implied. Use of third-party content does not indicate any affiliation, sponsorship with or endorsement by them. Any references to third-party content is to identify the corresponding services and shall be considered fair use under The CopyrightLaw.