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Double Tax Conventions
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Book Synopsis Schwarz on Tax Treaties by : Jonathan Schwarz
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Book Synopsis Introduction to the Law of Double Taxation Conventions by : Michael Lang
Download or read book Introduction to the Law of Double Taxation Conventions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2021-04-01 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Book Synopsis The Effect of Treaties on Foreign Direct Investment by : Karl P Sauvant
Download or read book The Effect of Treaties on Foreign Direct Investment written by Karl P Sauvant and published by Oxford University Press. This book was released on 2009-03-27 with total page 795 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
Book Synopsis Source Versus Residence by : Michael Lang
Download or read book Source Versus Residence written by Michael Lang and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version 2017 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2017 written by OECD and published by OECD Publishing. This book was released on 2017-12-18 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
Book Synopsis Double Taxation and the League of Nations by : Sunita Jogarajan
Download or read book Double Taxation and the League of Nations written by Sunita Jogarajan and published by Cambridge University Press. This book was released on 2018-05-10 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Book Synopsis Draft Double Taxation Convention on Income and Capital 1963 by :
Download or read book Draft Double Taxation Convention on Income and Capital 1963 written by and published by . This book was released on 1963 with total page 169 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 1963 report presents the articles on the avoidance of double taxation on income and capital, as agreed upon by the Fiscal Committee. Double taxation is the taxation of a single taxpayer with respect to the same subject matter over the same period in more than one country. This draft aims to inspire further conventions on the elimination of double taxation, a threat to trade and migration. The report includes commentaries on the articles, progress on the elimination of double taxation, and possible future developments.
Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Book Synopsis Interpretation and Application of Tax Treaties in North America by : Juan Angel Becerra
Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Book Synopsis Model Double Taxation Convention on Income and Capital 1977 by : OECD
Download or read book Model Double Taxation Convention on Income and Capital 1977 written by OECD and published by OECD Publishing. This book was released on 1977-10-19 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 1977 report contains the recommendations of the Committee on Fiscal Affairs for the avoidance of double taxation on income and capital. These recommendations result from consultation with member countries, following the 1963 Draft Convention. Double taxation is the taxation of a single ...
Book Synopsis Model Tax Convention on Income and on Capital 2017 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2017 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2019-04-25 with total page 2624 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Book Synopsis Double Taxation Within the European Union by : Alexander Rust
Download or read book Double Taxation Within the European Union written by Alexander Rust and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the conclusion of tax treaties and despite the enactment of several directives, double taxation continues to occur within the EU, causing severe obstacles for cross-border trade, for the provision of services and capital, and for the free movement of persons. This book collects the expert analysis and recommendations on the following issues: the reasons for the existence (and persistence) of juridical and economic double taxation; double burdens in criminal law; constitutional limits for double taxation; the Lisbon Treaty's abolition of Article 293 EC, which had required Member States to conclude tax treaties in order to abolish double taxation; whether double taxation can be avoided by the application of the four freedoms; prospects for an EU-wide multilateral tax treaty; the proposed Common Consolidated Corporate Tax Base; and use of arbitration clauses in tax treaties.
Author :United States. Congress. Joint Committee on Internal Revenue Taxation Publisher : ISBN 13 : Total Pages :1532 pages Book Rating :4.F/5 ( download)
Book Synopsis Legislative History of United States Tax Conventions by : United States. Congress. Joint Committee on Internal Revenue Taxation
Download or read book Legislative History of United States Tax Conventions written by United States. Congress. Joint Committee on Internal Revenue Taxation and published by . This book was released on 1962 with total page 1532 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Non-discrimination in Tax Treaty Law and World Trade Law by : Kasper Dziurdź
Download or read book Non-discrimination in Tax Treaty Law and World Trade Law written by Kasper Dziurdź and published by Kluwer Law International B.V.. This book was released on 2019-07-23 with total page 706 pages. Available in PDF, EPUB and Kindle. Book excerpt: Non-discrimination is a central obligation under both tax treaty and trade law. However, in seeking to strike a balance between national and international interests, its application differs in the two areas of practice. This deeply researched and authoritative work, which explains the policy issues and how non-discrimination analysis works, provides a comprehensive review of non-discrimination rules in WTO and tax treaty law, combining a critical commentary on case law with proposals for an innovative concept for solving cases of discrimination in tax treaty law. Among the practical issues affecting non-discrimination examined in detail are the following: implications that can be drawn from the concepts of non-discrimination under WTO law and Article 24 of the OECD Model; direct and indirect discrimination and analysis of comparability in WTO law and tax treaty law; the MFN and NT rules under the GATT and GATS; the meaning of ‘likeness’ and ‘less favourable treatment’; claiming non-discriminatory tax treatment before tax administrations and courts under a tax treaty; justification of measures against harmful tax competition, low taxation and hybrid mismatch arrangements; thin capitalisation rules, progressive tax rates, foreign losses, group taxation and relief from juridical and economic double taxation under Article 24 of the OECD Model; and integrating a justification defence into any stage of a non-discrimination analysis. The author establishes to what extent formal, substantive and subjective approaches may be applied in a non-discrimination analysis, providing the reasons for the approaches taken. A two-step comparability procedure is applied to selected cases of potential tax discrimination, demonstrating how policy arguments can be addressed under Article 24 of the OECD Model. Drawing on over a half-century of case law in both areas of practice, this comprehensive study of the non-discrimination rules under WTO law and international tax law will be invaluable in systematically solving cases of tax discrimination under Article 24 of the OECD Model and putting forward arguments at any stage of a WTO analysis. Policymakers will benefit from the author’s clear explanation of how national law should comply with international obligations. Also, taxpayers’ advisers will proceed confidently in claims of tax treaty discrimination, and academics will discover an incomparable overview and analysis of anti-discrimination rules in international trade law and double taxation conventions.
Author :Félix Daniel Martínez Laguna Publisher :Kluwer Law International B.V. ISBN 13 :9403510846 Total Pages :668 pages Book Rating :4.4/5 (35 download)
Book Synopsis Hybrid Financial Instruments, Double Non-Taxation and Linking Rules by : Félix Daniel Martínez Laguna
Download or read book Hybrid Financial Instruments, Double Non-Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 668 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
Download or read book U.S. Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Model Tax Convention on Income and on Capital 2014 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2014 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2015-10-30 with total page 2289 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014.
