Concept of employer : can a German permanent establishment of a foreign enterprise be a "resident employer"?

Resource Information

The work Concept of employer : can a German permanent establishment of a foreign enterprise be a "resident employer"? 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

Concept of employer : can a German permanent establishment of a foreign enterprise be a "resident employer"?

Subject

• employment income
• 183 days rule
• dependent personal services
• tax treaty
• PE

Language

eng

Summary

In the resolution the Supreme Tax Court considered the procedural aspects of a case in which the issue was whether or not an individual resident in Germany who was employed by a U.K. company that had a permanent establishment in Germany and who performed some services as an employee ebroad was subject to the German individual income tax with regard to the income that he received for the services performed abroad. This note examines the applicable tax treaty provisions and German national law and indicates how the Court reached its decision

Citation source

In: European taxation. - Amsterdam. - Vol. 22 (1983),

Geographic coverage

European Union

Language note

English