Renneberg endangers the double tax convention system or can a second round bring recovery?

Resource Information

The work Renneberg endangers the double tax convention system or can a second round bring recovery? represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

Renneberg endangers the double tax convention system or can a second round bring recovery?

Creator

• Kemmeren, E.C.C.M

Subject

• interest deduction
• ECJ case law
• mortgage
• owner-occupied dwelling
• immovable property
• tax treaty

Language

eng

Summary

This article discusses the Renneberg case. The case deals with the question of whether negative income from an owner-occupied dwelling should, because of a mortgage interest deduction, be taken into account in calculating the taxable base in the state of employment. Is this a case of allocation of tax jurisdiction on income from immovable property or a case of taking into account personal and family circumstances? The facts, circumstances, and assumptions in respect of this case are described. Subsequently, the relevant domestic and double tax convention rules are highlighted. Thereafter, the author discusses Advocate General Mengozzi's opinion and the European Court of Justice (ECJ) ruling

Citation source

In: EC tax review. - Alphen aan den Rijn. - Vol. 18 (2009),

Geographic coverage

• European Union
• Europe

Language note

English