Die "Subject-to-Tax"-Klausel in Art 15 Abs 4 DBA Österreich - Deutschland = The "subject to tax" clause in Art 15 sec 4 of the tax treaty between Austria and Germany

Resource Information

The work Die "Subject-to-Tax"-Klausel in Art 15 Abs 4 DBA Österreich - Deutschland = The "subject to tax" clause in Art 15 sec 4 of the tax treaty between Austria and Germany 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

Die "Subject-to-Tax"-Klausel in Art 15 Abs 4 DBA Österreich - Deutschland = The "subject to tax" clause in Art 15 sec 4 of the tax treaty between Austria and Germany

Creator

• Jirousek, H

Subject

• treaty interpretation
• cross-border worker
• subject to tax

Language

eng

Summary

Art 15 sec 4 of the tax treaty between Austria and Germany contains a "subject-to-tax" clause for income derived from employment. This clause allocates the taxation right to the state of residence in case of non-taxation of that income in the state of source. Sec 7 of the protocol to the tax treaty describes the scope of application of the clause by demanding that the respective activities have to be covered for tax purposes in the state of source. The author explains the general purpose of the provision and examines the validity of the clause in a triangular situation of a frontier worker

Citation source

In: Steuer und Wirtschaft International. - Wien. - Vol. 25 (2015),

Geographic coverage

Europe

Language note

German