The Attribution of Profits to Permanent Establishments

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Author :
Publisher : IBFD
ISBN 13 : 907607884X
Total Pages : 488 pages
Book Rating : 4.0/5 (76 download)

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Book Synopsis The Attribution of Profits to Permanent Establishments by : Raffaele Russo

Download or read book The Attribution of Profits to Permanent Establishments written by Raffaele Russo and published by IBFD. This book was released on 2005 with total page 488 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016

Courts and Tax Treaty Law

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Publisher : IBFD
ISBN 13 : 9087220138
Total Pages : 435 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Courts and Tax Treaty Law by : Guglielmo Maisto

Download or read book Courts and Tax Treaty Law written by Guglielmo Maisto and published by IBFD. This book was released on 2007 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.

Limitation on Benefits Clauses in Double Taxation Conventions

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041161430
Total Pages : 438 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Limitation on Benefits Clauses in Double Taxation Conventions by : Félix Alberto Vega Borrego

Download or read book Limitation on Benefits Clauses in Double Taxation Conventions written by Félix Alberto Vega Borrego and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 438 pages. Available in PDF, EPUB and Kindle. Book excerpt: Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.

Comentarios a la Ley del impuesto sobre la renta de no residentes

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Publisher : Aranzadi
ISBN 13 : 9788497672085
Total Pages : 589 pages
Book Rating : 4.6/5 (72 download)

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Book Synopsis Comentarios a la Ley del impuesto sobre la renta de no residentes by : Andrés Sánchez López

Download or read book Comentarios a la Ley del impuesto sobre la renta de no residentes written by Andrés Sánchez López and published by Aranzadi. This book was released on 2003-01-01 with total page 589 pages. Available in PDF, EPUB and Kindle. Book excerpt:

EC Tax Review

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Publisher :
ISBN 13 :
Total Pages : 728 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis EC Tax Review by :

Download or read book EC Tax Review written by and published by . This book was released on 2002 with total page 728 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Comentarios a la Ley del impuesto sobre la renta de no residentes

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Author :
Publisher : Civitas Book Publisher
ISBN 13 : 9788447012572
Total Pages : 503 pages
Book Rating : 4.0/5 (125 download)

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Book Synopsis Comentarios a la Ley del impuesto sobre la renta de no residentes by : Angel Baena Aguilar

Download or read book Comentarios a la Ley del impuesto sobre la renta de no residentes written by Angel Baena Aguilar and published by Civitas Book Publisher. This book was released on 1999-01-01 with total page 503 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Bulletin for International Fiscal Documentation

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Publisher :
ISBN 13 :
Total Pages : 652 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Bulletin for International Fiscal Documentation by : International Bureau of Fiscal Documentation

Download or read book Bulletin for International Fiscal Documentation written by International Bureau of Fiscal Documentation and published by . This book was released on 1999 with total page 652 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Differences in Tax Treatment Between Local and Foreign Investors and Effects of International Treaties

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Author :
Publisher : Springer
ISBN 13 :
Total Pages : 516 pages
Book Rating : 4.3/5 (512 download)

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Book Synopsis Differences in Tax Treatment Between Local and Foreign Investors and Effects of International Treaties by : International Fiscal Association Staff

Download or read book Differences in Tax Treatment Between Local and Foreign Investors and Effects of International Treaties written by International Fiscal Association Staff and published by Springer. This book was released on 1978-02-01 with total page 516 pages. Available in PDF, EPUB and Kindle. Book excerpt: Of national reports on the topic by various contributors participating in the 32nd congress of the International Fiscal Association which was held in Sydney, 1978. The report by the general reporter J. van Hoorn is published in full in four languages.

Annual Legal Bibliography

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Publisher :
ISBN 13 :
Total Pages : 784 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Annual Legal Bibliography by : Harvard Law School. Library

Download or read book Annual Legal Bibliography written by Harvard Law School. Library and published by . This book was released on 1981 with total page 784 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Glosario Del Banco Mundial

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Publisher : World Bank Publications
ISBN 13 :
Total Pages : 468 pages
Book Rating : 4.:/5 (318 download)

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Book Synopsis Glosario Del Banco Mundial by : World Bank

Download or read book Glosario Del Banco Mundial written by World Bank and published by World Bank Publications. This book was released on 1996 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt: This edition of the World Bank has been revised and expanded by the Terminology Unit in the Languages Services Division of the World Bank in collaboration with the English, Spanish, and French Translation Sections. The Glossary is intended to assist the Bank's translators and interpreters, other Bank staff using French and Spanish in their work, and free-lance translator's and interpreters employed by the Bank. For this reason, the Glossary contains not only financial and economic terminology and terms relating to the Bank's procedures and practices, but also terms that frequently occur in Bank documents, and others for which the Bank has a preferred equivalent. Although many of these terms, relating to such fields as agriculture, education, energy, housing, law, technology, and transportation, could be found in other sources, they have been assembled here for ease of reference. A list of acronyms occurring frequently in Bank texts (the terms to which they refer being found in the Glossary) and a list of international, regional, and national organizations will be found at the end of the Glossary.

Die Regeln für die Einordnung von Einnahmen und Ausgaben als inländische oder ausländische

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Author :
Publisher : Springer
ISBN 13 :
Total Pages : 696 pages
Book Rating : 4.3/5 (512 download)

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Book Synopsis Die Regeln für die Einordnung von Einnahmen und Ausgaben als inländische oder ausländische by :

Download or read book Die Regeln für die Einordnung von Einnahmen und Ausgaben als inländische oder ausländische written by and published by Springer. This book was released on 1980 with total page 696 pages. Available in PDF, EPUB and Kindle. Book excerpt: Of national reports on the topic delivered at the 34th congress of the International Fiscal Association which was held in Paris, 1980. The report by the general reporter is published in full in four languages.

Commitment to Equity Handbook

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Publisher : Brookings Institution Press
ISBN 13 : 0815740476
Total Pages : 1437 pages
Book Rating : 4.8/5 (157 download)

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Book Synopsis Commitment to Equity Handbook by : Nora Lustig

Download or read book Commitment to Equity Handbook written by Nora Lustig and published by Brookings Institution Press. This book was released on 2023-05-01 with total page 1437 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Nora Lustig, the Commitment to Equity Handbook: Estimating the Impact of Fiscal Policy on Inequality and Poverty (Brookings Institution Press and CEQ Institute-Tulane University, 2nd edition, 2022) is a unique manual on the theory and practical methods to estimate the impact of taxation and public spending on inequality and poverty. In addition, the second edition covers frontier topics such as alternative approaches to measure the redistributive effect of education, health, and infrastructure spending. Policymakers, social planners, and economists are provided with a step-by-step guide to applying fiscal incidence analysis, illustrated by country studies. The 2nd edition of the Handbook has two volumes. Volume 1 is comprised of Part I, Methodology, describes what a CEQ Assessment© is and presents the theoretical underpinnings of fiscal incidence analysis and the indicators used to assess the distributive impact and effectiveness of fiscal policy. Part II, Implementation, presents the methodology on how taxes, subsidies, and social spending should be allocated. It includes a step-by step guide to completing the CEQ Master Workbook©, a multi-sheet Excel file that houses detailed information on the country’s fiscal system and the results used as inputs for policy discussions, academic papers, and policy reports. Part III, “Applications,” presents applications of the CEQ framework to low- and middle-income countries and includes simulations of policy reforms. In this 2nd edition, chapters 1, 6, and 8 have been significantly updated and two new country studies have been added to Part III. Parts IV (updated), V (new), and VI (new) are available online only. Part IV contains the CEQ Assessment’s main tools. Part V includes the databases housed in the CEQ Data Center on Fiscal Redistribution. Part VI contains the CEQ Institute’s microsimulation tools. Volume 2 (new) includes a collection of chapters whose purpose is to expand the knowledge and methodological frontiers to sharpen even further the analysis of fiscal policy’s redistributive impact. Topics include: alternative approaches to value in-kind education and health services; alternative methods to evaluate spending on infrastructure; corporate taxes and taxation on capital incomes; inter-temporal fiscal incidence and the redistributive consequences of social insurance pensions; fiscal redistribution, macroeconomic stability and growth; and, the political economy of fiscal redistribution.

Tax Management Portfolios

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Publisher :
ISBN 13 :
Total Pages : 316 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Tax Management Portfolios by :

Download or read book Tax Management Portfolios written by and published by . This book was released on 2002 with total page 316 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Recueil Des Traités

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Publisher :
ISBN 13 :
Total Pages : 524 pages
Book Rating : 4.3/5 (121 download)

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Book Synopsis Recueil Des Traités by :

Download or read book Recueil Des Traités written by and published by . This book was released on 2000 with total page 524 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Medical and Dental Expenses

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Publisher :
ISBN 13 :
Total Pages : 20 pages
Book Rating : 4.:/5 (3 download)

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Book Synopsis Medical and Dental Expenses by :

Download or read book Medical and Dental Expenses written by and published by . This book was released on 1990 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt:

National Union Catalog

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Publisher :
ISBN 13 :
Total Pages : 744 pages
Book Rating : 4.:/5 (89 download)

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Book Synopsis National Union Catalog by :

Download or read book National Union Catalog written by and published by . This book was released on 1968 with total page 744 pages. Available in PDF, EPUB and Kindle. Book excerpt: Includes entries for maps and atlases.

Pension and Annuity Income

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Publisher :
ISBN 13 :
Total Pages : 32 pages
Book Rating : 4.3/5 (126 download)

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Book Synopsis Pension and Annuity Income by : United States. Internal Revenue Service

Download or read book Pension and Annuity Income written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: