23 July 1991 External T.I. 911980 F - Sale of Real Estate in Germany

By services, 18 January, 2022
Official title
Sale of Real Estate in Germany
Language
French
CRA tags
n/a
Document number
Citation name
911980
Severed letter type
Technical Interpretation - External
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
631012
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1991-07-23 08:00:00",
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Main text

Dear Sirs:

Re:  Sale of Real Estate in Germany

This is in reply to your letter dated July 15, 1991 whereby you inquired concerning the application of the Agreement between Canada and the Federal Republic of Germany for the Avoidance of Double Taxation With Respect to Taxes on Income and Certain Other Taxes signed in 1981, as amended (the "Agreement") in respect of the sale of real estate situate in what was East Germany (prior to the recent unification) by a resident of Canada.

We enclose herewith a copy of the News Release dated June 26, 1991 respecting the announcement of the National Revenue Minister that the Agreement now applies to the unified Germany.

We confirm that, as anticipated by you, we are not in a position to advise concerning the German tax laws.  We recommend that you contact the German taxation authorities directly in order to obtain further information concerning taxation by Germany under its domestic laws.

Yours truly,

for DirectorReorganizations and Non-Resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch