AG Opinion Issued on Dispute Involving Austria-Germany Tax Treaty and the Limits of Its Jurisdiction in Resolving Such Disputes

On 27 April 2017, an opinion was issued from Advocate General (AG) Mengozzi of the CJEU regarding the interpretation of the interest provisions in the 2000 Austria-Germany tax treaty as amended by the 2010 protocol, as well as the limits of the CJEU's jurisdiction in resolving such disputes. Addressing the limits of jurisdiction is a key aspect of the opinion as this is the first time a Member State has brought before the Court, pursuant to Article 273 TFEU, a dispute, between it and another …