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Dokumentvorschau
SWI 10, Oktober 1999, Seite 422

Doppelbesteuerungsabkommen mit Deutschland paraphiert

TAX TREATY WITH GERMANY INITIALLED

Helmut Loukota

A new tax treaty between Austria and Germany was initialled on 2 September, 1999, which shall replace the old convention concluded in 1954. The event took place in Paris, where the heads of the two delegations attended a meeting of the OECD forum on harmful tax practices and where final success could be reached in bridging the remaining open points of the deviating positions with regard to the anti-avoidance-clauses of the treaty. Germany had been interested to incorporate as many anti-avoidance-clauses as possible into the treaty whereas Austria had to take care that this was not carried out in a discriminatory way as compared to tax treaties concluded by Germany with the other Members of the European Union and of the European Economic Area. Once more the negotiations have revealed the necessity of a multilateral tax convention within the European Community. If there had been such a treaty many of the difficulties could have been avoided since many of the Austrian arguments against the German initiatives were not so much directed against the anti-avoidance-clauses as such, but against their discriminatory effect on economic investments in Austria.

I. Zum zeitlichen Ablauf der Abkom...

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