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Die DBA-rechtliche Beurteilung von Gesamtproduktionen

SWI 2018, 529

In the field of art and culture, contracts may contain different obligations, including administrative and supportive activities, which are not covered by Art 17 OECD Model Tax Convention (OECD MC). When the income of an entertainer is derived by another person who performs services other than those of an artistic nature, it is questionable whether the whole sum paid by the promoter is subject to Art 17 OECD MC or the payment has to be split. Stefanie Geringer summarizes the decision of the German Federal Fiscal Court on this topic and puts the court’s opinion in relation to the wording of the OECD MC Commentary, earlier decisions of the Austrian Supreme Administrative Court and Austrian tax treaties.