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| Germany, Liechtenstein Sign DTA |
by Ulrika Lomas, Tax-News.com, Brussels
Monday, November 21, 2011
The Principality of Liechtenstein and the Federal Republic of Germany have
recently signed in Berlin a bilateral double taxation agreement (DTA) between
the two countries, intended to secure mutual legal, planning and investment
security.
During the signing, German Finance Minister Wolfgang Schäuble and Liechtenstein’s
Prime Minister Klaus Tschütscher highlighted the fact that improved tax
relations resulting from the agreement would serve to strengthen and to promote
the very close economic ties between the two countries.
Outlining the cornerstones of the agreement, the finance ministries of Germany
and Liechtenstein emphasized that the text would provide a solid basis for mutual
investments. The ministries pointed out that the DTA would provide for a 0% withholding tax rate on payment of certain dividends, interest and royalties.
According to the ministries, the DTA also contains regulations designed to
prevent misuse of the treaty, to ensure that the agreement is not used as a
means to evade taxes, as well as a comprehensive binding arbitration clause.
In their joint release, the ministries alluded to the tax information exchange agreement signed by the
principality and Germany back in September 2009. In accordance with the Organization
for Economic Cooperation and Development’s standard, providing
for cooperation and for an exchange of information in tax matters, the agreement
entered into force in October 2010.
The latest DTA marks a further significant step towards deepening cooperation
in the area of taxation, the ministries added.
While underscoring that the agreement does not contain provisions pertaining
to a procedure for taxing German investors’ undeclared income in Liechtenstein banks, the ministries
underscored that these issues would form the focus of separate discussions between the two countries.
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