Advocate General Mengozzi has given an opinion in the case Austria v Germany.

Mengozzi proposes that the Court should hold that the phrase ‘income from rights or debt-claims with participation in profits', contained in Article 11(2) of the Convention of 24 August 2000 between Austria and Germany for the avoidance of double taxation with respect to taxes on income and capital must be interpreted as meaning that it covers income which provides a creditor with a part or a share of the debtor's profits, to the exclusion of income which varies only in the event of losses incurred by that debtor.  



Informatiesoort: Nieuws

Rubriek: Europees belastingrecht, Internationaal belastingrecht

H&I: Previews


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