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Irish Tax Treaties 2006 07
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Book Synopsis Irish Tax Treaties 2006-07 by : Mary Walsh
Download or read book Irish Tax Treaties 2006-07 written by Mary Walsh and published by Bloomsbury Professional. This book was released on 2006-07-01 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains all the Double Taxation Agreements entered into by Ireland along with the latest OECD Model Tax Convention including the commentary thereon as well as the UN Model Tax Treaty plus its commentary. This new edition also contains other interpretation agreements, useful tables and relevant EU material.
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 Tax Treaties and Domestic Law by : Guglielmo Maisto
Download or read book Tax Treaties and Domestic Law written by Guglielmo Maisto and published by IBFD. This book was released on 2006 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Book Synopsis Treaties by : United States. Congress. Senate. Committee on Foreign Relations
Download or read book Treaties written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 2008 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Other Income under Tax Treaties by : Alexander Bosman
Download or read book Other Income under Tax Treaties written by Alexander Bosman and published by Kluwer Law International B.V.. This book was released on 2015-09-23 with total page 610 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bilateral tax treaties are often, to a greater or lesser extent, based on the OECD Model Convention. Among the distributive rules with respect to taxation of income which are laid down in Chapter III of that model, Article 21 assigns the tax jurisdiction in respect of "other income" - understood to mean items of income which are not dealt with in other provisions of the tax treaty - to the residence state in accordance with the main rule underlying the OECD Model, thus ensuring that no income falls outside the scope of the treaty. This study provides a comprehensive analysis of Article 21 of the OECD Model. In extensive detail, and with reference to case law from a number of jurisdictions and to statements of various authorities and official documents, the author shows how Article 21 operates in relation to the other distributive rules of the OECD Model and bilateral tax treaties based thereon. The analysis considers such items of income as the following in relation to Article 21: - income from immovable property; - business profits; - profits from shipping, inland waterways transport, and air transport; - dividends, interest, and royalties; - capital gains; and - income from employment. In addition, the author examines the significance of the OECD Commentaries for the interpretation of tax treaties, the "other income" article in other model conventions, and notable deviations from Article 21 among bilateral tax treaties. An appendix offers well-grounded recommendations on how to potentially amend the wording of Article 21 and the related commentary and how the application of the article can be improved. Although underexposed in the tax law literature heretofore, the "other income" article raises important international taxation issues that remain problematic or unresolved. Tax lawyers, government officials, and other interested professionals will find here a penetrating analysis that goes a long way towards clarifying the characterisation of income that resists the standard categories defined in tax treaties.
Book Synopsis Ireland in International Tax Planning by : Charles Haccius
Download or read book Ireland in International Tax Planning written by Charles Haccius and published by IBFD. This book was released on 2004 with total page 1399 pages. Available in PDF, EPUB and Kindle. Book excerpt: Revised and updated edition providing the introduction to Irish tax legislation, along with an explanation of the effect of treaty relief. The discussion of treaties includes practical comparison with the OECD Model Convention and the effect on treaty relief of the Constitution of Ireland. Follows practical discussion of Ireland's tax breaks, beginning with a discussion of the circumstances in which a company resident or carrying on business in Ireland qualifies for the 12.5% rate of corporation tax, and continuing with the issues of the tax efficient establishment and financing of a trading presence in Ireland, whether through a subsidiary or a permanent establishment or both. Possible tax planning opportunities are then discussed, both long standing tax breaks such as relief for artists and inventors, forestry, bloodstock and foreign domiciliaries, and opportunities such as those arising from the exercise of an employment in Ireland and the employment of crew members employed on ships or aircraft by an Irish resident company. The book also discusses transfer pricing and anti-avoidance provisions both in the Irish domestic tax legislation and in tax treaties.
Book Synopsis A Global Analysis of Tax Treaty Disputes by : Eduardo Baistrocchi
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Book Synopsis Klaus Vogel on Double Taxation Conventions by : Ekkehart Reimert
Download or read book Klaus Vogel on Double Taxation Conventions written by Ekkehart Reimert and published by Kluwer Law International B.V.. This book was released on 2022-01-18 with total page 3112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University
Book Synopsis Tax Planning with Holding Companies - Repatriation of US Profits from Europe by : Rolf Eicke
Download or read book Tax Planning with Holding Companies - Repatriation of US Profits from Europe written by Rolf Eicke and published by Kluwer Law International B.V.. This book was released on 2009-01-01 with total page 526 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Book Synopsis Tax Treaty Case Law around the Globe 2019 by : Michael Lang
Download or read book Tax Treaty Case Law around the Globe 2019 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2020-07-22 with total page 309 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Book Synopsis Double Taxation Agreements by : Pat O'Brien
Download or read book Double Taxation Agreements written by Pat O'Brien and published by . This book was released on 1998 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Convention with Ireland by : United States. Congress. Senate. Committee on Foreign Relations
Download or read book Tax Convention with Ireland written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1997 with total page 62 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Internal Revenue Bulletin by : United States. Internal Revenue Service
Download or read book Internal Revenue Bulletin written by United States. Internal Revenue Service and published by . This book was released on 2007-05-14 with total page 752 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Social Work in Northern Ireland by : Heenan, Deirdre
Download or read book Social Work in Northern Ireland written by Heenan, Deirdre and published by Policy Press. This book was released on 2011-03-23 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past 40 years, social work in Northern Ireland has been responsive to a number of changing contexts and environments. Throughout 'the Troubles,' social workers had to develop methods of ensuring services were delivered in spite of the surrounding violence and civil disturbance. At the same time, they developed imaginative and creative new services in response to needs and demands. This book outlines the historical development of social work in Northern Ireland, looking at what has been achieved and analyzing the challenges for the future. It considers the role of social work in a society emerging from conflict, facing demographic, technological, and economic changes. Social work in Northern Ireland has been dismissed by policy makers and academics as unique, special, or different, and therefore not worthy of attention. This book demonstrates that international audiences have much to learn from the social work response to a changing political landscape.
Book Synopsis Tax Treaty Case Law around the Globe 2022 by : Eric Kemmeren
Download or read book Tax Treaty Case Law around the Globe 2022 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2023-11-29 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that provides a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases that were decided around the world in 2021. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2022 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Book Synopsis Tax Treaty Case Law around the Globe 2021 by : Georg Kofler
Download or read book Tax Treaty Case Law around the Globe 2021 written by Georg Kofler and published by Linde Verlag GmbH. This book was released on 2022-07-19 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the thirty most important tax treaty cases that were decided around the world in 2020. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, "Tax Treaty Case Law around the Globe 2021" is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.
Book Synopsis Irish Capital Gains Tax 2021 by : Tom Maguire
Download or read book Irish Capital Gains Tax 2021 written by Tom Maguire and published by Bloomsbury Publishing. This book was released on 2021-09-23 with total page 1426 pages. Available in PDF, EPUB and Kindle. Book excerpt: Irish Capital Gains Tax provides in-depth analysis and interpretation of the law as it is applied to CGT by the Irish and UK courts as well as in Appeal Commissioners' decisions. It includes commentary on Revenue guidance, the administration of CGT as well as the computational rules and key reliefs and allowances. Topics covered range from the tax treatment of married couples, partnerships, companies and trusts to anti-avoidance. This new edition has been updated to take account of the Finance Act 2020. Contents include: Statutory interpretation; What is an asset; What is a disposal; Persons chargeable; Married couples and civil partnerships; Taxation of partnerships; Computational rules; Shares; Financial instruments; Debts; Trusts; Anti-avoidance; Companies; Residence; Foreign tax matters; CA 2014 transactions.
