Judgment_paragraph 36 · FKP Scorpio Konzertproduktionen GmbH v Finanzamt Hamburg-Eimsbüttel (C-290/04)

36The procedure of retention at source and the liability rules supporting it constitute a legitimate and appropriate means of ensuring the tax treatment of the income of a person established outside the State of taxation and ensuring that the income concerned does not escape taxation in the State of residence and the State where the services are provided. It should be recalled that at the material time, in 1993, no Community directive or any other instrument referred to in the case-file governed mutual administrative assistance concerning the recovery of tax debts between the Kingdom of the Netherlands and the Federal Republic of Germany.

FKP Scorpio Konzertproduktionen GmbH v Finanzamt Hamburg-Eimsbüttel (C-290/04)

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