Peter Pendler is a natural person and has a residence in Kleve and a residence in Paris/France. Thefamily lives in Kleve, but during the whole week, the taxpayer has to

stay in Paris, because there is hisfulltime job. Only comes to Germany during the holidays (2x a year for 3 weeks each) and for someweekends, if possible. Has a French passport only. France has, like Germany, the rule that, under domestic law, every person is subjected to unlimited tax liability who has a residence in the country. - 1. Income from the job in Paris: 60.000 EUR 2. Income from the job during the time when he has to do some bsn travels to Germany: 2.000EUR. Such travels took 5 single days this year. 3. Gain from selling a German piece of land: 5.000 EUR 4. Rent from a house in Germany: 3.000, and from a French piece of land: 5.000 EUR ASSUME that the DTT Germany-France is exactly identical to the OECD-Model Convention.Germany and France both apply article 23 in the variant 23A.