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Ireland Treaties And Tax Information Exchange Agreements
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Book Synopsis Ireland: Treaties and Tax Information Exchange Agreements by : U. S. Department U.S. Department of the Treasury
Download or read book Ireland: Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by . This book was released on 2014-11-07 with total page 106 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Convention between the United States and Ireland and the Protocol signed on July 28, 1997 (the "Convention" and "Protocol"). References are made to the Convention between the Government of the United States of America and the Government of Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on September 13, 1949 (the "prior Convention"). The Convention replaces the prior Convention.In connection with the negotiation of the Convention and the Protocol, the negotiators developed and agreed upon an exchange of diplomatic notes. The notes constitute an agreement between the two governments which shall enter into force at the same time as the entry into force of the Convention. These understandings and interpretations are intended to give guidance both to the taxpayers and the tax authorities of both Contracting States in interpreting the relevant provisions of the Convention.Negotiations took into account the U.S. Treasury Department's current tax treaty policy, the Model Income Tax Convention on Income and on Capital, published by the OECD in 1992 and amended in 1994 and 1995 (the "OECD Model") and recent tax treaties concluded by both countries. References to the "U.S. Model" refer to the U.S. Treasury Department's Model Income Tax Convention of September 20, 1996, which was issued after negotiation of the Convention was substantially completed, although prior drafts of the U.S. Model were available and taken into account in the course of negotiations.
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503127357 Total Pages :100 pages Book Rating :4.1/5 (273 download)
Book Synopsis Hungary: Treaties and Tax Information Exchange Agreements by : U. S. Department U.S. Department of the Treasury
Download or read book Hungary: Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a Technical Explanation of the Convention between the Government of the United States and the Government of the Republic of Hungary for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on February 4, 2010 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the Treasury Department's Model Income Tax Convention. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries.1 The Technical Explanation is an official guide to the Convention and an accompanying Exchange of Notes. It reflects the policies behind particular provisions in the Convention and Exchange of Notes, as well as understandings reached during the negotiations with respect to the application and interpretation of the Convention and Exchange of Notes. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his and her."
Book Synopsis France: Treaties and Tax Information Exchange Agreements by : U. S. Department U.S. Department of the Treasury
Download or read book France: Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by . This book was released on 2014-11-07 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Protocol and the related Memorandum of Understanding signed at Paris on January 13, 2009 (hereinafter the "Protocol" and "Memorandum of Understanding" respectively), amending the Convention between the Government of the United States of America and the Government of the French Republic for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital, signed at Paris on August 31, 1994, as amended by the Protocol signed on December 8, 2004 (together, the "existing Convention"). Negotiations took into account the U.S. Department of the Treasury's current tax treaty policy and the Treasury Department's Model Income Tax Convention, published on November 15, 2006 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries. This Technical Explanation is an official guide to the Protocol and Memorandum of Understanding. It explains policies behind particular provisions, as well as understandings reached during the negotiations with respect to the interpretation and application of the Protocol and Memorandum of Understanding. References to the "existing Convention" are intended to put various provisions of the Protocol into context. The Technical Explanation does not, however, provide a complete comparison between the provisions of the existing Convention and the amendments made by the Protocol. The Technical Explanation is not intended to provide a complete guide to the existing Convention as amended by the Protocol and Memorandum of Understanding. To the extent that the existing Convention has not been amended by the Protocol and Memorandum of Understanding, the Technical Explanations of the Convention signed at Paris on August 31, 1994 (the "1994 Convention") and the Protocol signed on December 8, 2004 (the "2004 Protocol") remain the official explanation. To the extent that a paragraph from the 1994 Convention or the 2004 Protocol has not been changed, the technical explanations to the 1994 Convention and the 2004 Protocol, respectively, remain the official explanation. References in this Technical Explanation to "he" or "his" should be read to mean "he or she" or "his or her." References to the "Code" are to the Internal Revenue Code of 1986, as amended.
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503127340 Total Pages :80 pages Book Rating :4.1/5 (273 download)
Book Synopsis Iceland by : U. S. Department U.S. Department of the Treasury
Download or read book Iceland written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Convention between the Government of the United States and the Government of Iceland For the Avoidance Of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on October 23, 2007 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the Treasury Department's Model Income Tax Convention. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Convention and an accompanying Protocol. It reflects the policies behind particular Convention and Protocol provisions, as well as understandings reached during the negotiations with respect to the application and interpretation of the Convention and Protocol. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his and her."
Book Synopsis Spain: Treaties and Tax Information Exchange Agreements by : U. S. Department U.S. Department of the Treasury
Download or read book Spain: Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by . This book was released on 2014-11-07 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a Technical Explanation of the Protocol signed at Washington on January 14, 2013, the related Memorandum of Understanding signed the same day, and a subsequent Exchange of Notes dated July 23, 2013 (hereinafter the "Protocol", "Memorandum of Understanding" and "Exchange of Notes" respectively), amending the Convention between the United States of America and the Kingdom of Spain for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Madrid on February 22, 1990 (hereinafter the "existing Convention") and the Protocol, which forms an integral part of the existing Convention, signed at Washington on November 6, 2003 (hereinafter the "Protocol of 1990"). Negotiations took into account the U.S. Department of the Treasury's current tax treaty policy and the Treasury Department's Model Income Tax Convention, published on November 15, 2006 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries. This Technical Explanation is an official guide to the Protocol, Memorandum of Understanding and Exchange of Notes. It explains policies behind particular provisions, as well as understandings reached during the negotiations with respect to the interpretation and application of the Protocol, Memorandum of Understanding and the Exchange of Notes.
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503127456 Total Pages :110 pages Book Rating :4.1/5 (274 download)
Book Synopsis Belgium: Treaties and Tax Information Exchange Agreements by : U. S. Department U.S. Department of the Treasury
Download or read book Belgium: Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 110 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Convention between the Government of the United States of America and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Brussels on November 27, 2006 (the "Convention"), and the Protocol also signed at Brussels on November 27, 2006, which forms an integral part thereto (the "Protocol"). The Protocol is discussed below in connection with relevant provisions of the Convention. References are made to the Convention between the Government of the United States of America and the Government of the Kingdom of Belgium for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Brussels on July 9, 1970, as amended by protocol signed December 31, 1987 (the "prior Convention"). The Convention and Protocol replace the prior Convention. Negotiations took into account the U.S. Treasury Department's current tax treaty policy and the Treasury Department's Model Income Tax Convention, published on November 15, 2006 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his and her."
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503142404 Total Pages :42 pages Book Rating :4.1/5 (424 download)
Book Synopsis The Netherlands by : U. S. Department U.S. Department of the Treasury
Download or read book The Netherlands written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-08 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Protocol signed at Washington on March 8, 2004 (the "Protocol"), amending the Convention between the United States of America and the Kingdom of the Netherlands for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Washington on December 18, 1992 (the "1992 Convention"), as amended by a protocol signed at Washington on October 13, 1993 (the "1993 Protocol"). The term "Convention" refers to the 1992 Convention as modified by both the 1993 Protocol and the Protocol. Negotiations took into account the U.S. Treasury Department's current tax treaty policy and the Treasury Department's Model Income Tax Convention, published on September 20, 1996 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development, as updated in January 2003 (the "OECD Model"), and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Protocol. It reflects the policies behind particular Protocol provisions, as well as understand ings reached with respect to the application and interpretation of the Protocol and the 1992 Convention. This Technical Explanation should be read together with the Technical Explanation to the 1992 Convention with respect to provisions that have not been modified. The Protocol was accompanied by a detailed Understanding, implemented through an exchange of notes, indicating the views of the negotiators and of the States with respect to a number of provisions of the Convention. The Understanding supersedes the Understanding accompanying the 1992 Convention and the related exchange of notes accompanying the 1993 Protocol. The portions of the Understanding that have been added (as opposed to being merely repeated) are discussed in connection with the relevant portions of the Protocol.
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503130524 Total Pages :100 pages Book Rating :4.1/5 (35 download)
Book Synopsis Poland by : U. S. Department U.S. Department of the Treasury
Download or read book Poland written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 100 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a Technical Explanation of the Convention between the United States and the Republic of Poland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Warsaw on February 13, 2013 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the Treasury Department's Model Income Tax Convention, published on November 15, 2006 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by the United States and Poland. The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached during the negotiations with respect to the application and interpretation of the Convention. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his or her," respectively. References to the "Code" are to the Internal Revenue Code of 1986, as amended. References to a "Treas. Reg." are to regulations issued under the Code by the Internal Revenue Service and the Treasury Department.
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503127388 Total Pages :38 pages Book Rating :4.1/5 (273 download)
Book Synopsis Finland by : U. S. Department U.S. Department of the Treasury
Download or read book Finland written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Protocol signed at Washington on May 31, 2006 (the "Protocol"), amending the Convention between the United States of America and the Government of Finland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, signed at Helsinki on September 21, 1989 (the "Convention"). Negotiations took into account the U.S. Department of the Treasury's current tax treaty policy and Treasury's Model Income Tax Convention, published on September 20, 1996 (the "U.S. Model"). Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries. This Technical Explanation is an official guide to the Protocol. It explains policies behind particular provisions, as well as understandings reached during the negotiations with respect to the interpretation and application of the Protocol. This technical explanation is not intended to provide a complete guide to the Convention as amended by the Protocol. To the extent that the Convention has not been amended by the Protocol, the Technical Explanation of the Convention remains the official explanation. References in this technical explanation to "he" or "his" should be read to mean "he or she" or "his or her."
Book Synopsis Germany: Treaties and Tax Information Exchange Agreements by : U. S. Department U.S. Department of the Treasury
Download or read book Germany: Treaties and Tax Information Exchange Agreements written by U. S. Department U.S. Department of the Treasury and published by . This book was released on 2014-11-07 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Protocol signed at Berlin on June 1, 2006 (the "Protocol"), amending the Convention between the United States of America and the Federal Republic of Germany for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital and to certain other taxes, and the related protocol, signed at Bonn on August 29, 1989 (hereinafter the "Convention" and "Protocol to the Convention" respectively). Negotiations took into account the U.S. Department of the Treasury's current tax treaty policy and Treasury's Model Income Tax Convention, published on September 20, 1996 (the "1996 U.S. Model").1 Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organisation for Economic Cooperation and Development (the "OECD Model"), and recent tax treaties concluded by both countries. This Technical Explanation is an official guide to the Protocol. It explains policies behind particular provisions, as well as understandings reached during the negotiations with respect to the interpretation and application of the Protocol. This technical explanation is not intended to provide a complete guide to the Convention as amended by the Protocol. To the extent that the Convention has not been amended by the Protocol, the Technical Explanation of the Convention remains the official explanation. Moreover, Article XVI of the Protocol restates and updates the Protocol to the Convention. This technical explanation discusses only those aspects of Article XVI that amend the Protocol to the Convention. To the extent that a paragraph from the Protocol to the Convention has not been changed, the technical explanation to the Convention remains the official explanation. References in this technical explanation to "he" or "his" should be read to mean "he or she" or "his or her."
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503130579 Total Pages :106 pages Book Rating :4.1/5 (35 download)
Book Synopsis Italy by : U. S. Department U.S. Department of the Treasury
Download or read book Italy written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 106 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Convention and the Protocol between the United States and the Italian Republic signed on August 25, 1999 (the "Convention" and the "Protocol"). References are made to the Convention between the United States and Italy for the Avoidance of Double Taxation with Respect to Taxes on Income and the Prevention of Fraud or Fiscal Evasion, signed on April 17, 1984 (the "prior Convention"). The Convention replaces the prior Convention. Negotiations took into account the U.S. Treasury Department's current tax treaty policy, as reflected in the U.S. Treasury Department's Model Income Tax Convention of September 20, 1996 (the "U.S. Model") and its recently negotiated tax treaties, the Model Income Tax Convention on Income and on Capital, published by the OECD in 1992 and amended in 1994, 1995 and 1997 (the "OECD Model"), and recent tax treaties concluded by Italy. In connection with the negotiation of the Convention and the Protocol, the negotiators developed and agreed upon a Memorandum of Understanding. The Memorandum of Understanding is a statement of intent setting forth a common understanding and interpretation of certain provisions of the Convention and Protocol reached by the delegations of the United States and Italy acting on behalf of their respective governments. These understandings and interpretations are intended to give guidance both to the taxpayers and the tax authorities of both Contracting States in interpreting the relevant provisions of the Convention and Protocol. The Technical Explanation is an official guide to the Convention and Protocol. It reflects the policies behind particular Convention and Protocol provisions, as well as understandings reached with respect to the application and interpretation of the Convention and Protocol. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" and "his or her."
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503142398 Total Pages :132 pages Book Rating :4.1/5 (423 download)
Book Synopsis United Kingdom by : U. S. Department U.S. Department of the Treasury
Download or read book United Kingdom written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-08 with total page 132 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Convention between the United States and the United Kingdom of Great Britain and Northern Ireland, signed on July 24, 2001 (the "Convention"), as amended by the Protocol between the United States and the United Kingdom of Great Britain and Northern Ireland, signed on July 22, 2002 (the "Protocol"). References are made to the Convention between the Government of the United States of America and the Government of the United Kingdom of Great Britain and Northern Ireland for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital Gains, signed on December 31, 1975, as amended by Protocols signed on August 26, 1976, March 31, 1977, and March 15, 1979 (the "prior Convention"). The Convention replaces the prior Convention. In connection with the negotiation of the Convention, the delegations of the United States and the United Kingdom developed and agreed upon an exchange of diplomatic notes (the "notes"). The notes constitute an agreement between the two governments that shall enter into force at the same time as the entry into force of the Convention. These understandings and interpretations are intended to give guidance both to the taxpayers and to the tax authorities of the Contracting States in interpreting the Convention. The notes are discussed below in connection with relevant provisions of the Convention. In connection with the negotiation of the Convention, the delegations of the United States and the United Kingdom developed and agreed upon an exchange of diplomatic notes (the "notes"). The notes constitute an agreement between the two governments that shall enter into force at the same time as the entry into force of the Convention. These understandings and interpretations are intended to give guidance both to the taxpayers and to the tax authorities of the Contracting States in interpreting the Convention. The notes are discussed below in connection with relevant provisions of the Convention. The notes provide that the United States and the United Kingdom will consult together at regular intervals regarding the terms, operation and application of the Convention to ensure that it continues to serve the purposes of avoiding double taxation and preventing fiscal evasion. The first such consultation will take place no later than December 31st of the fifth year following the date on which the Convention enters into force in accordance with the provisions of Article 29 (Entry into Force). Further consultations shall take place thereafter at intervals of no more than five years. The notes also provide that the United States and the United Kingdom will conclude further protocols to amend the Convention, if appropriate.
Book Synopsis Taxation, Information Exchange by : Great Britain
Download or read book Taxation, Information Exchange written by Great Britain and published by . This book was released on 1994 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :U. S. Department U.S. Department of the Treasury Publisher :CreateSpace ISBN 13 :9781503130517 Total Pages :92 pages Book Rating :4.1/5 (35 download)
Book Synopsis Slovenia by : U. S. Department U.S. Department of the Treasury
Download or read book Slovenia written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 92 pages. Available in PDF, EPUB and Kindle. Book excerpt: Negotiations took into account the U.S. Treasury Department's current tax treaty policy, and the U.S. Treasury Department's Model Income Tax Convention published on September 30, 1996. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development, as updated in November, 1997 (the "OECD Model") and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Convention. It reflects the policies behind particular Convention provisions, as well as understandings reached with respect to the application and interpretation of the Convention. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his or her".
Book Synopsis Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition by : OECD
Download or read book Standard for Automatic Exchange of Financial Account Information in Tax Matters, Second Edition written by OECD and published by OECD Publishing. This book was released on 2017-03-27 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains the following four parts: A model Competent Authority Agreement (CAA) for the automatic exchange of CRS information; the Common Reporting Standard; the Commentaries on the CAA and the CRS; and the CRS XML Schema User Guide.
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 A Practitioner's Guide To International Tax Information Exchange Regimes by : Harriet Brown
Download or read book A Practitioner's Guide To International Tax Information Exchange Regimes written by Harriet Brown and published by Spiramus Press Ltd. This book was released on 2021-09-01 with total page 414 pages. Available in PDF, EPUB and Kindle. Book excerpt: The recent introduction of the Directive on Administrative Cooperation in the field of taxation 6 (DAC6) and mandatory disclosure regimes by many jurisdictions have led to a large number of professionals potentially being required to disclose information in relation to their clients’ arrangements. The authors analyse the operation of the various automatic exchange of information regimes which have been introduced in the last five years including the OECD common reporting standards DAC6 and MDR. They set them in their historical context as well as giving a technical analysis of the regimes. They focus on the guidance offered by the Irish and UK tax authorities with reference to other guidance in Europe and beyond, where appropriate.
