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| Author: | Wattel, P.J. |
| Title: | The Schumacker legacy introduction Taxing non-resident employees: coping with Schumacker |
| Journal: | European Taxation
1995 : NOV/DEC, VOL. 35:11-12, p. 347-353 |
| Index terms: | INTERNATIONAL TAXATION INTERNATIONAL ORGANIZATIONS FOREIGN WORKERS |
| Language: | eng |
| Abstract: | In its Schumacker decision, the Court of Justice of the European Communities tried to reconcile the European non-discrimination principle with the common differential treatment of resident and non-resident taxpayers in international tax law. As was to be expected, these two prove to be irreconcilable. The Court therefore made a compromise: non-residents may fiscally be discriminated against, unless they earn their income entirely or almost exclusively in the work state and do not earn enough income in their home state to be able to benefit from the home state personal allowances. |
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