Judgment_paragraph 32 · Finanzamt Köln-Altstadt v Roland Schumacker (C-279/93)

32Income received in the territory of a Member State by a nonresident is in most cases only a part of his total income, which is concentrated at his place of residence. Moreover, a nonresident's personal ability to pay tax, determined by reference to his aggregate income and his personal and family circumstances, is more easy to assess at the place where his personal and financial interests are centred. In general, that is the place where he has his usual abode. Accordingly, international tax law, and in particular the Model Double Taxation Treaty of the Organization for Economic Cooperation and Development (OECD), recognizes that in principle the overall taxation of taxpayers, taking account of their personal and family circumstances, is a matter for the State of residence.

Finanzamt Köln-Altstadt v Roland Schumacker (C-279/93)

Key facts

History · 1 version

Connections