In this article, the author examines a recent decision by the Court of Appeal of Ghent (Belgium) regarding the qualification for tax treaty purposes of image rights payments derived by a non-resident professional football player, active in the Belgian first division

This article examines the decision in Austria v. Germany (Case C-648/15), which was submitted to the ECJ pursuant to the Austria–Germany Income and Capital Tax Treaty (2000). The author examines (1) the EU law aspects of the decision, in particular the Court’s jurisdiction to hear tax treaty...