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Germany - Tax Treaty Interpretation in Germany: Utilizing the OECD’s New Approach to the Qualification of Income

Adrian Cloer, Franziska Sixdorf

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Abstract

The authors, in this note, present the decision of the Lower Fiscal Court of Berlin-Brandenburg in Case 15 K 1093/10 regarding the qualification of income for the purposes of applying tax treaties, including a discussion of its implications on tax treaty interpretation in Germany.

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The authors, in this note, present the decision of the Lower Fiscal Court of Berlin-Brandenburg in Case 15 K 1093/10 regarding the qualification of income for the purposes of applying tax treaties, including a discussion of its implications on tax treaty interpretation in Germany.

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Available abstract

The authors, in this note, present the decision of the Lower Fiscal Court of Berlin-Brandenburg in Case 15 K 1093/10 regarding the qualification of income for the purposes of applying tax treaties, including a discussion of its implications on tax treaty interpretation in Germany.

Key concepts: Interpretation (philosophy), Tax treaty, Treaty, Economics, Income tax, International economics, Political science, Public economics

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