Double tax agreements determine taxing rights between countries. They do not create new taxation rights. Rather, where competing rights exist, they allocate the taxation right to only one of the countries involved, to prevent double taxation.
A list of Germany's double taxation agreements with over 90 countries can be found here. Most of these follow the international OECD model convention. National tax rules do provide, subject to tax clauses, to avoid untaxed income (called 'white income' as well) (ITA, s 50d).
Where a German resident individual is subjected to cross border taxation that cannot be mitigated through a double taxation agreement, the taxpayer can request a comprise from the Federal Central Tax Office (Bundeszentralamt für Steuern – BZSt) in accordance with the provisions contained in most treaties for an arbitration procedure.
Most double tax treaties signed by Germany apply the tax exemption method for employment income subject to taxation abroad. The exemption is provided only if the taxation abroad was in line with the double tax treaty and if the foreign income tax was paid accordingly. The proof of
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Web page updated on 17 Mar 2025 14:25