The new German unilateral switch-over and subject-to-tax rule

• Autores: Richard Xenophon Resch
• Localización: European taxation, ISSN 0014-3138, Vol. 47, Nº. 10, 2007, págs. 480-483
• Idioma: inglés
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• Resumen

  • Germany is in the process of introducing sweeping measures to counter tax avoidance. A new unilateral switch-over and subject-to-tax provision has been introduced and the anti-treaty-shopping rule has been tightened. Further measures to combat transfers of profits outside Germany and revisions to the general anti-abuse rule are under way. This article addresses the unilateral switch-over and subject-to-tax provision and its compatibility with treaty law.