Translation and interpretation of the Ministry of Finance letter regarding the application of Germany’s unilateral subject-to-tax-clause (‘unilaterale Rückfallklausel’) for the taxation of flight crews resident in Germany working for British and Irish Airlines
(German/ English version)
Inhaltsverzeichnis (Table of Contents)
- I. INTRODUCTION
- II. TRANSLATION: TAXATION OF FLIGHT CREWS RESIDENT IN GERMANY WORKING FOR BRITISH AND IRISH AIRLINES
- III. REMARKS AUTHOR
- V. FINAL COMMENTS
Zielsetzung und Themenschwerpunkte (Objectives and Key Themes)
The objective of this document is to provide an understanding of Germany's unilateral subject-to-tax clause, using a Ministry of Finance letter as a practical example. The translation and commentary aim to familiarize international tax experts and advisors with this specific aspect of German tax law.
- Germany's unilateral subject-to-tax clause
- Taxation of flight crews resident in Germany working for foreign airlines
- Interpretation of tax treaties in relation to domestic tax law
- Potential for "treaty override" situations
- Cross-border tax implications
Zusammenfassung der Kapitel (Chapter Summaries)
I. INTRODUCTION: This chapter introduces the difficulty of navigating cross-border tax issues and explains the purpose of the document: to provide a better understanding of Germany's unilateral subject-to-tax clause through the translation and analysis of a relevant Ministry of Finance letter.
II. TRANSLATION: TAXATION OF FLIGHT CREWS RESIDENT IN GERMANY WORKING FOR BRITISH AND IRISH AIRLINES: This section presents a translation of the Ministry of Finance letter, focusing on the application of the unilateral subject-to-tax clause in a specific case involving flight crews.
III. REMARKS AUTHOR: This chapter provides the author's commentary and analysis on the translated Ministry of Finance letter, offering further insight into the practical application of the unilateral subject-to-tax clause.
Schlüsselwörter (Keywords)
Unilateral subject-to-tax clause, German tax law, international taxation, tax treaties, flight crews, cross-border taxation, treaty override, Ministry of Finance, tax planning, dependent personal services.
- Citation du texte
- Dipl. Finanzwirt (FH), MITax, Steuerberater Ruediger Urbahns (Auteur), 2009, Germany’s unilateral subject-to-tax-clause, Munich, GRIN Verlag, https://www.grin.com/document/123267
