Statement of Trust Income Allocations and Designations [ Statement of Trust Income Allocations ]

Reconciliation Statement - Revenue Trust Account

In situations where more than one Member State has taxing rights over income, the CJ has confirmed that Member States are free to allocate taxing rights between themselves[85]. They usually do so on the basis of bilateral double taxation conventions.

Given its effect on the regional distribution of economic activity and income, the control of state aid remains of major importance in the context of enlargement.

A fixed range increases the harmonising effect, while maintaining a certain level of flexibility for Member States to set the threshold in function of the particular situation in their labour market, their average income levels and divergence in income distribution.

A natural person who is a citizen or resident of a Contracting State and a beneficiary of a trust, company, organization or other arrangement that is a resident of the other Contracting State, generally exempt from income taxation in that other State and operated exclusively to provide pension, retirement or employee benefits may elect to defer taxation in the first-mentioned State, under rules established by the competent authority of that State, with respect to any income accrued in the plan but not distributed by the plan, until such time as and to the extent that a distribution is made from the plan or any plan substituted therefor”.