France Administrative Court of Appeal of Marseille Clarifies Tax Liability With Germany, Switzerland Under DTAs

The French Court of Appeal of Marseille Sept. 22 issued Decision No. 25MA00518, clarifying tax liability for individuals under the DTAs with Germany and Switzerland. The taxpayer, a divorced individual tax resident in France, sought to discharge additional individual income tax and social security contributions. The Administrative Court of Toulon denied the discharge. On appeal, the Court of Appeal of Marseille found that: 1) the taxpayer was taxable on German private pension income in Germany and France, and there was no evidence he was taxed by Germany and suffered double taxation; 2) absent proof that certain amounts corresponded to income ...