Übersetzung für "Double taxation convention" in Deutsch

Furthermore, that obstacle cannot be justified by the existence of a double taxation convention.

Although it is true that any Member State which has concluded a double taxation convention must implement it

The alleged is applied unless otherwise is regulated by the Double Taxation Convention.

For the purposes of this Agreement, the term ‘permanent establishment’ shall have the meaning that it has under the relevant double taxation convention between Switzerland and the State of residence of the debtor.

For the purposes of this Agreement, the term "permanent establishment" shall have the meaning that it has under the relevant double taxation convention between Switzerland and the State of residence of the debtor.

Each Member State having concluded a double taxation convention with a third country not complying with minimum standards as set out in point 3 should, as most appropriate with a view to improve compliance by that third country with these standards, either seek to renegotiate the convention, suspend or terminate the convention.

In accordance with the double taxation convention between the two States concerned, the estate of a national of a Member State who dies within 10 years of ceasing to reside in that Member State was to be taxed as if that national had continued to reside in that Member State.

Between 1988 and 1995, where the loan was granted by a non-resident company to a resident subsidiary, all the interest was treated as a distributed profit save where there was a provision to contrary effect in a double taxation convention (DTC).

The double taxation convention also stipulated that the taxing State would reduce the tax so due by the amount of tax due in the other State by reason of residence there.

Following the adoption of two Directives abolishing certain forms of double taxation and a convention on transfer pricing, two new supplementary measures are envisaged.

As far as the taxation of the pilot's salaries is concerned, the Bilateral Double Taxation Convention between Belgium and Luxembourg determines the taxing rights between these two countries.

A Member State which has waived its tax powers by concluding a double taxation convention cannot rely on the lack of tax powers with respect to the results of a permanent establishment which belongs to a company established in the territory of that State in order to justify the refusal to deduct expenditure incurred by that company which, by its nature, cannot be taken into account in the Member State where that establishment is situated.

Where therefore such income is exempt from German tax pursuant to a double taxation convention, the currency loss cannot be brought into the company’s assessment to German tax.

Since the activity in Luxembourg was essentially restricted to administration of haulage operations and major decisions concerning that company were taken solely by Mr Hoves, who was domiciled in Germany and, for the most part, resided there, the company's place of management within the meaning of Article 3(6) of the Luxembourg/Germany Double Taxation Convention of 23 August 1958, in its amended version of 15 July (read: June) 1973 was not in Luxembourg, but in Germany.

However, a clear answer could not be given as to whether the offices in Remich and Esch/Alzette (Luxembourg) were a permanent establishment within the meaning of the Double Taxation Convention.

In the light of the foregoing, the answer to Question 1(a) must be that Articles 56 EC and 58 EC do not preclude legislation of a Member State, such as the legislation at issue in the main proceedings, which grants a concession to fiscal investment enterprises established in that Member State on account of tax deducted at source in another Member State from dividends received by those enterprises, and restricts that concession to the amount which a natural person resident in the first Member State could have had credited, on account of similar deductions, on the basis of a double taxation convention concluded with that other Member State.

Article 7(2) of Directive 90/435 is to be interpreted as allowing taxation such as the 5% charge envisaged by the double taxation convention at issue in the main proceedings even though that charge, in so far as it applies to dividends paid by the subsidiary to its parent company, amounts to a withholding tax within the meaning of Article 5(1) of the Directive.

As regards taxes not covered by a double taxation convention, the Commission would like to ask the Honourable Member to indicate in more detail which kind of taxes he means.

Furthermore, Article 26 of the OECD's model double taxation convention is now worded so that it is no longer permissible for a country to invoke the excuse – used frequently in the past – that information requested by a contracting state cannot be provided because it is held by a bank, for example.

Awareness of the double taxation convention between the source country and Hungary is vital of course, but generally speaking, interest and capital gains are taxable in the country of residence.

In order to prevent foreigners from paying taxes both in Germany and in their home country, Germany has entered into a so-called Double Taxation Convention with many countries.

If you remain in Germany for less than half a year (183 days), your income will be taxed in your home country if you have worked for a foreign employer and if the Double Taxation Convention gives the right of taxation to your home country.

Another positive effect came from a contribution of EUR 5.7 million from a mutual tax agreement procedure in accordance with the Double Taxation Convention between Germany and the USA, which was brought to a successful conclusion faster than expected.