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