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Incongruencies in Double Taxation Conventions

Published online by Cambridge University Press:  12 February 2016

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Abstract

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Type
Legislation
Copyright
Copyright © Cambridge University Press and The Faculty of Law, The Hebrew University of Jerusalem 1973

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References

1 Signed July 9, 1962, and entered into force on August 21, 1966. Published in Germany in BGBI 1966 II, 329, and in Israel in K.A. Vol. 16, No. 615 of January 1, 1967, pp. 219–258, and No. 258a of even date, pp. 258A–258H.

2 Originally enacted under the British Mandate in 1941 and in Israel published in a consolidated version on April 25, 1961; since then 13 amendments have been enacted.

3 Land Appreciation Tax (1963), Sefer HaHukim 405, pp. 156 ff.Google Scholar (with amendments).

4 Grunderwerbsteuergesetz March 29, 1940 (RGBI I, S. 585).

5 Grundgesetz May 23, 1949 (BGBI, p. 1, and BGBI, III, 100–1).

6 Income Tax Ordinance, Chapter 5, secs. 88–100.

7 Finanzgericht, Nuernberg, file No. IV, 118 (68), published in “Entscheidungen internationaler Steuerfaelle”. Jahrgang 1970, pp. 79–80.

8 Finanzministerium Nordrhein—Westfalen, Order, July 23, 1970, S. 1301—Ägypten 2—VB3 with consent of the Federal Finance Ministry and the Finance Ministers of the various “Laender”. The case was especially interesting because the Egyptian Finance Ministry had promised the licensee not to levy any Egyptian net wealth tax in Egypt if it would be introduced there in case the German Federal Republic would exempt from the German net wealth tax licences which a German licensor would grant to an Egyptian licensee. Should the U.A.R. introduce a net wealth tax the German tax authorities would under sec. 10(2) Vermögensteuergesetz be instructed to exempt Egyptian licences granted to German enterprises from that tax in U.A.R.

9 Gewerbesteuergesetz, October 20, 1969.

10 Bewertungsgesetz, October 16, 1934.

11 Revised Text of Certain Articles, O.E.C.D. publication, no. 84.697.

12 Law for the Encouragement of Capital Investments, (1969) Se jer HaHukim 293, pp. 234 ff.Google Scholar (with seven amendments).

13 Law for the Encouragement of Industry (Taxes), (1969) Sefer HaHukim 572Google Scholar, (with one amendment).