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Paula Anna Jenner on Muck Rack

Paula Anna Jenner

As seen in: JD Supra, Mondaq, aoshearman.com
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Articles

Interest On Withholding Tax Refunds In Cases Of Incorrect Application Of A Double Tax Treaty

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By Florian Lechner, Paula Anna Jenner
| Mondaq
Florian Lechner’s articles from A&O Shearman are most popular: in European Union in European Union in European Union in European Union with readers working within the Technology and Media & Information industries A&O Shearman are most popular: within Insolvency/Bankruptcy/Re-Structuring, Strategy and Consumer Protection topic(s) In its judgment of March 26, 2026, case no.
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Interest on withholding tax refunds in cases of incorrect application of a double tax treaty

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By Paula Anna Jenner, Florian Lechner
| JD Supra
In its judgment of March 26, 2026, case no. 6 K 2820/20, the Cologne Fiscal Court ruled that a claim under EU law to interest on tax refunds may exist even where a tax refund was initially refused due to the incorrect application of a double taxation agreement.
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Interest on withholding tax refunds in cases of incorrect application of a double tax treaty

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By Florian Lechner, Paula Anna Jenner
| aoshearman.com
Summary The claimant, an Austrian bank, had received payments from profit participation certificates issued by German banks between 2003 and 2008, on which withholding tax and solidarity surcharge had been withheld. The refund was initially refused on the grounds of a German taxation right under Article 11 para. 2 of the Austria-Germany Double Taxation Agreement.
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