Local tax court holds that a server qualifies as a permanent establishment

Journal
Author
Eicker, K.
Country
Germany; Switzerland
Published Date
Issue
International Transfer Pricing Journal 2002 (Volume 9), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The local tax court of Schleswig-Holstein judged that a server owned by a German-based information broker and deployed in Switzerland, qualifies as a permanent establishment under Arts. 7 and 5(1) of the Germany-Switzerland tax treaty.