International Tax Policy and Double Tax Treaties

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Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)

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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.

Double Taxation Relief for Shipping

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Publisher :
ISBN 13 :
Total Pages : 376 pages
Book Rating : 4.3/5 (5 download)

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Book Synopsis Double Taxation Relief for Shipping by : Ralph Newns

Download or read book Double Taxation Relief for Shipping written by Ralph Newns and published by . This book was released on 1988 with total page 376 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reproduction of the text of double taxation relief provisions for shipping income from 105 agreements between the United Kingdom and its trading partners extracted from comprehensive income tax treaties and limited double taxation relief agreements on shipping and air transport.

Introduction to the Law of Double Taxation Conventions

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Author :
Publisher : Linde Verlag GmbH
ISBN 13 : 3709408628
Total Pages : 266 pages
Book Rating : 4.7/5 (94 download)

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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.

Investment Fund Taxation

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Publisher : Kluwer Law International B.V.
ISBN 13 : 904119679X
Total Pages : 361 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Investment Fund Taxation by : Werner Haslehner

Download or read book Investment Fund Taxation written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2017-04-24 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: The effect of the significant changes in tax law at domestic, European, and international levels on investment funds, an important part of global financial services, creates a complex environment for practitioners and a source of debate for academics and policymakers. This is the first book to provide a comprehensive legal and practical analysis of the changes to the complex multilevel tax and regulatory framework concerning different types of investment funds. The contributions, updated as of late 2017, were originally presented at a conference held at the University of Luxembourg in November 2016 under the auspices of the ATOZ Chair for European and International Taxation. The book covers the central questions arising in national law and tax policy, explores the regulatory and tax framework of the European Union (EU), and discusses the multifaceted interactions of both national and EU law with bilateral tax treaties. Through fourteen chapters following a brief introduction, leading academic experts and practising specialists provide decisive insight into: – the regulatory regime for European investment funds; – the tax law and reforms in both Luxembourg and Germany; – the role of the European Commission’s State-aid practices; – examples of case law concerning the application of non-discrimination rules to various investment vehicles; – the impact of tax-specific EU legislation, such as the Parent-Subsidiary Directive, the Tax Merger Directive, and the Anti-Tax Avoidance Directive; – the availability of tax treaty protection for different collective and non-collective investment funds; – the impact of base erosion and profit shifting (BEPS) developments on the taxation of cross-border investments; – the value-added tax (VAT) treatment of investment funds and their managers; and – the consequences of the global drive towards automatic exchange of information relating to existing cross-border investment structures. With its particular focus on Luxembourg – the leading centre for investment funds in Europe (and second only to the United States globally) and, thus, an instructive model for domestic-level investment fund regulation and taxation – this volume reveals the common issues that arise in virtually every other jurisdiction with a sizeable fund industry. As the first in-depth treatment of the globally significant nexus between investment funds and taxation, the book will prove valuable to policymakers, practitioners, and academics in both financial services and tax law.

Switzerland in International Tax Law

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Publisher : IBFD
ISBN 13 : 9087220987
Total Pages : 457 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Switzerland in International Tax Law by : Xavier Oberson

Download or read book Switzerland in International Tax Law written by Xavier Oberson and published by IBFD. This book was released on 2011 with total page 457 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).

Time and Tax: Issues in International, EU, and Constitutional Law

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403501642
Total Pages : 434 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Time and Tax: Issues in International, EU, and Constitutional Law by : Werner Haslehner

Download or read book Time and Tax: Issues in International, EU, and Constitutional Law written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 434 pages. Available in PDF, EPUB and Kindle. Book excerpt: Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.

Non-discrimination in Tax Treaty Law and World Trade Law

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9403509120
Total Pages : 706 pages
Book Rating : 4.4/5 (35 download)

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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.

The Public International Law of Taxation

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Publisher : Kluwer Law International B.V.
ISBN 13 : 9041184775
Total Pages : 912 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis The Public International Law of Taxation by : Asif H. Qureshi

Download or read book The Public International Law of Taxation written by Asif H. Qureshi and published by Kluwer Law International B.V.. This book was released on 2019-05-22 with total page 912 pages. Available in PDF, EPUB and Kindle. Book excerpt: The phenomenal internationalization of taxation occurring in recent years has called for a second edition of this classic handbook. Even though a quarter of a century has passed, the farsighted first edition has remained in constant use worldwide and has even grown in importance. Now it has been thoroughly updated by the author, who has brought his piercing insight to bear on the current world of international tax law while retaining the book’s practical format, structure of primary materials, and detailed commentary. Emphasizing the need for an international consciousness in relation to issues of taxation, Professor Qureshi focuses extensively on the problems associated with fiscal jurisdiction, international constraints in domestic taxation, double taxation, and tax evasion and avoidance. In particular the following are covered: treaty law with specific reference to taxation; fiscal aspects of international monetary, investment, and trade law; enforcement of international tax claims; exchange of information; assistance in recovery of tax claims; mechanisms for the resolution of international tax disputes; base erosion and profit shifting in the framework of public international law; and contribution of international institutions to fiscal capacity development. Assimilating in one source the basic materials in public international law germane to taxation – including cases, texts of international agreements, discourse in secondary sources, and incisive commentary, all updated to the present – this new edition of the most authoritative and important book in its field will be of immeasurable value to tax practitioners worldwide, national taxation authorities, international institutions, and the international tax community more generally.

Guide to Government Orders

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Publisher :
ISBN 13 :
Total Pages : 1434 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Guide to Government Orders by : Great Britain

Download or read book Guide to Government Orders written by Great Britain and published by . This book was released on 1960 with total page 1434 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Shipping and Aircraft Tax Agreement Between the United States and the People's Republic of China

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Publisher :
ISBN 13 :
Total Pages : 16 pages
Book Rating : 4.:/5 (327 download)

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Book Synopsis Shipping and Aircraft Tax Agreement Between the United States and the People's Republic of China by :

Download or read book Shipping and Aircraft Tax Agreement Between the United States and the People's Republic of China written by and published by . This book was released on 1983 with total page 16 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Statutory Instruments

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Publisher :
ISBN 13 :
Total Pages : 1764 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Statutory Instruments by : Great Britain

Download or read book Statutory Instruments written by Great Britain and published by . This book was released on 1961 with total page 1764 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Ship Registration: Law and Practice

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Publisher : Taylor & Francis
ISBN 13 : 1135118310
Total Pages : 753 pages
Book Rating : 4.1/5 (351 download)

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Book Synopsis Ship Registration: Law and Practice by : Edward Watt

Download or read book Ship Registration: Law and Practice written by Edward Watt and published by Taylor & Francis. This book was released on 2013-07-04 with total page 753 pages. Available in PDF, EPUB and Kindle. Book excerpt: The expanded and fully updated second edition include detailed coverage of additional flag states; an examination of the implications of the ISM and ISPS Codes and the requirements of the Large Yacht Code as they relate to ship registration; a new introductory chapter describing the legal and practical requirements of ship registration; and a fresh analysis of the status and usage of national and open registries in current practice.

Double Taxation Relief

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Publisher :
ISBN 13 :
Total Pages : 36 pages
Book Rating : 4.:/5 (31 download)

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Book Synopsis Double Taxation Relief by : Mitchell Benedict Carroll

Download or read book Double Taxation Relief written by Mitchell Benedict Carroll and published by . This book was released on 1928 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fixing U.S. International Taxation

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Publisher : Oxford University Press, USA
ISBN 13 : 019935975X
Total Pages : 242 pages
Book Rating : 4.1/5 (993 download)

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Book Synopsis Fixing U.S. International Taxation by : Daniel N. Shaviro

Download or read book Fixing U.S. International Taxation written by Daniel N. Shaviro and published by Oxford University Press, USA. This book was released on 2014-04 with total page 242 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fixing U.S. International Taxation provides a major rethinking of the tax issues raised by cross-border investment and the activities of multinational corporations.

Double Taxation and the League of Nations

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Publisher : Cambridge University Press
ISBN 13 : 1108383742
Total Pages : 356 pages
Book Rating : 4.1/5 (83 download)

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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.

Double Taxation and Fiscal Evasion

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Publisher :
ISBN 13 :
Total Pages : 468 pages
Book Rating : 4.3/5 ( download)

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Book Synopsis Double Taxation and Fiscal Evasion by : League of Nations. Economic and Financial Section

Download or read book Double Taxation and Fiscal Evasion written by League of Nations. Economic and Financial Section and published by . This book was released on 1928 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt:

The Statutory Rules and Orders Revised

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Publisher :
ISBN 13 :
Total Pages : 1126 pages
Book Rating : 4.:/5 (49 download)

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Book Synopsis The Statutory Rules and Orders Revised by : Great Britain

Download or read book The Statutory Rules and Orders Revised written by Great Britain and published by . This book was released on 1951 with total page 1126 pages. Available in PDF, EPUB and Kindle. Book excerpt: