The Status of Mutual Agreement between the Netherlands and Germany on the Allocation of Severance Payments

F.P.G. Potgens; E.M.L Kool

The Status of Mutual Agreement between the Netherlands and Germany on the Allocation of Severance Payments

F.P.G. Potgens
, E.M.L Kool

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Abstract

The Netherlands Supreme Court has ruled that, under article 10 (income from dependent personal services) of the former Germany-Netherlands Income Tax Treaty (1959), severance payments should be allocated according to the Court’s previous case law. Any conflicting result that may be arrived at by the competent authorities of the two contracting states under a mutual agreement procedure (under article 25(2) of the Treaty) must not be allowed to disadvantage the relevant taxpayer.

Original language	English
Pages (from-to)	526-530
Number of pages	5
Journal	European Taxation
Volume	58
Issue number	11
Early online date	12 Oct 2018
Publication status	Published - Nov 2018

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Netherlands - The Status of Mutual Agreement between the Netherlands and Germany on the Allocation of Severance Payments - IBFDFinal published version, 276 KBLicence: Article 25fa Dutch Copyright Act

https://research.ibfd.org/#/doc?url=/collections/et/html/et_2018_11_nl_1.html

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abstract = "The Netherlands Supreme Court has ruled that, under article 10 (income from dependent personal services) of the former Germany-Netherlands Income Tax Treaty (1959), severance payments should be allocated according to the Court{\textquoteright}s previous case law. Any conflicting result that may be arrived at by the competent authorities of the two contracting states under a mutual agreement procedure (under article 25(2) of the Treaty) must not be allowed to disadvantage the relevant taxpayer.",

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N2 - The Netherlands Supreme Court has ruled that, under article 10 (income from dependent personal services) of the former Germany-Netherlands Income Tax Treaty (1959), severance payments should be allocated according to the Court’s previous case law. Any conflicting result that may be arrived at by the competent authorities of the two contracting states under a mutual agreement procedure (under article 25(2) of the Treaty) must not be allowed to disadvantage the relevant taxpayer.

AB - The Netherlands Supreme Court has ruled that, under article 10 (income from dependent personal services) of the former Germany-Netherlands Income Tax Treaty (1959), severance payments should be allocated according to the Court’s previous case law. Any conflicting result that may be arrived at by the competent authorities of the two contracting states under a mutual agreement procedure (under article 25(2) of the Treaty) must not be allowed to disadvantage the relevant taxpayer.

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EP - 530

JO - European Taxation

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The Status of Mutual Agreement between the Netherlands and Germany on the Allocation of Severance Payments

Abstract

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