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

Journal
Germany
European Taxation 2017 (Volume 57), No. 7
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.