"Double taxation agreement between Liechtenstein and Germany"

The double taxation agreement (DTA) between Liechtenstein and Germany, which came into force on January 1, 2013, aims to improve tax relations and expand economic relations. It largely follows the OECD Model Tax Convention, but contains specific regulations. For example, terms such as "person" and "company" have been defined more comprehensively and special residency rules have been laid down in the protocol.

With the DTA, Liechtenstein is introducing the new "Authorized OECD Approach" for the first time, which regards permanent establishments as independent entities. For dividends, interest and licenses, a reduction in withholding tax to 0% was agreed under certain conditions. The agreement avoids double taxation through exemption and imputation methods and contains anti-abuse provisions to prevent tax avoidance.

The DTA with Liechtenstein provides a reliable basis for investment and international cooperation and shows Liechtenstein to be an attractive tax location.

Topics in the publication

• Double taxation agreements (DTA)
• International tax policy
• OECD Model Tax Convention
• Definitions of terms
• Residency rules
• Corporate profits
• Dividends, interest and royalties
• Avoidance of double taxation
• Anti-abuse provisions
• Real economy clause