Rather than slavishly following the order of the Treaty, this Practical Guide breaks down the type of income to be taxed into the main categories which are treated in different ways under the Treaty. The major areas covered are:
pure or passive income, i.e. investment income where the recipient does not earn by the provision of goods or services;
income derived from independent activities, such as trading or professional activities by individuals, partnerships and companies; and
the activities of sportsmen and entertainers.
The book also deals with activities in which an individual is bound more closely to a particular company employer or former employer, thus covering income from employment, directorships or pensions. Each section is cross-referenced to the relevant Treaty articles and there is a comprehensive index. Three useful appendices list the forms needed to make claims under the Treaty, and give the text of the Treaty in both English and German.
Although the subject matter may initially appear technical and obscure, the book is both clearly written and sensibly structured to give the reader simple access to the most difficult topics.
