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Issues In International Taxation Model Tax Convention Four Related Studies
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Book Synopsis Issues in International Taxation Model Tax Convention: Four Related Studies by : OECD
Download or read book Issues in International Taxation Model Tax Convention: Four Related Studies written by OECD and published by OECD Publishing. This book was released on 1992-12-23 with total page 97 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication, includes four recent reports of the Committee on Fiscal Affairs that have resulted in changes to the Commentary of the Model Tax Convention on Income and on Capital.
Author :Organisation for Economic Co-operation and Development Publisher :Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications Information Centre ISBN 13 : Total Pages :112 pages Book Rating :4.3/5 (91 download)
Book Synopsis Model Tax Convention by : Organisation for Economic Co-operation and Development
Download or read book Model Tax Convention written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications Information Centre. This book was released on 1992 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Four reports of the OECD that have resulted in changes to the Commentary of the Model Tax Convention on Income and on Capital. The studies deal with the computation of the 183-day rule of sub-paragraph 2b) of Article 15 of the Model, the application of tax conventions to "triangular cases", the tax treatment of software payments and the tax treatment of employees' contributions to foreign pension schemes.
Book Synopsis Issues in International Taxation International Tax Avoidance and Evasion Four Related Studies by : OECD
Download or read book Issues in International Taxation International Tax Avoidance and Evasion Four Related Studies written by OECD and published by OECD Publishing. This book was released on 1987-04-30 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first report outlines the reasons why international tax avoidance and evasion through the use of tax havens is a concern to the tax authorities of OECD Member countries and examines measures introduced to combat such use. The second report sets out the problems posed for tax administrations by the fact that their resident taxpayers make use of base companies (generally subsidiary companies) in tax havens to shelter there income derived from source countries (which may in some cases be the residence country itself) and in that way to escape tax normally payable to the country of residence. The third report deals with the problems created for tax authorities in source countries by the mechanism of "treaty shopping". The final report deals with taxation and the abuse of bank secrecy.
Author :Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs Publisher :Organization for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Centre ISBN 13 : Total Pages :124 pages Book Rating :4.:/5 (318 download)
Book Synopsis International Tax Avoidance and Evasion by : Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Download or read book International Tax Avoidance and Evasion written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by Organization for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Centre. This book was released on 1987 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of four related studies.
Book Synopsis Essays on International Taxation by : Dhruv Sanghavi
Download or read book Essays on International Taxation written by Dhruv Sanghavi and published by Bloomsbury Publishing. This book was released on 2020-12-21 with total page 530 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom
Author :Organisation for Economic Co-operation and Development Publisher :Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications and Information Centre ISBN 13 : Total Pages :60 pages Book Rating :4.3/5 (91 download)
Book Synopsis Model Tax Convention by : Organisation for Economic Co-operation and Development
Download or read book Model Tax Convention written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications and Information Centre. This book was released on 1994 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication examines the circumstances under which income is to be attributed to a permanent establishment for purposes of an income tax treaty, particularly where goods, services, or intangibles are transferrred between the permanent establishment and the home office or another permanent establishment in a third country.
Book Synopsis Models with Impact, Or Merely Conventional Examples? A Quantitative Exploration of the Relationship Between the UN Model Convention and the Bilateral Treaty Network on the Issue of the Taxation of Services by : M. A. Lemmens
Download or read book Models with Impact, Or Merely Conventional Examples? A Quantitative Exploration of the Relationship Between the UN Model Convention and the Bilateral Treaty Network on the Issue of the Taxation of Services written by M. A. Lemmens and published by . This book was released on 2016 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt: States need revenue to provide for the common basic needs in order for a society to prosper. Taxation is the key source of revenue. As of this importance, taxation remains a policy field in which state sovereignty persists. However, the globalizing world puts pressure on the sovereignty. The international taxation regime, consisting of bilateral treaties, domestic law and model conventions, is evolved to face its challenges. The relationships within this international taxation regime is the topic of this research, more specifically the relationship between model conventions and the bilateral treaty network. A quantitative analysis using the IBFD Tax Treaty Database provides insight in some key trends in the bilateral treaty network with regard to three articles on the taxation of services: the deemed service permanent establishment, the broadened royalty article, and the separate service fee withholding tax article. The result is that there does not seem to be a significant relationship between the UN Model Convention and the bilateral treaties on this highly political topic. Therefore, it seems that one should think twice about promoting model conventions in order to solve problems or faults in this regime that surpass technical and administrative issues.
Book Synopsis Tax Treaty Interpretation by : Sergio André Rocha
Download or read book Tax Treaty Interpretation written by Sergio André Rocha and published by . This book was released on 2022-11-28 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Because the normative concepts referred to in tax treaties are susceptible to contextual variation, the rules embedded in such treaties cannot be applied without interpretation. In this incomparable book, an internationally known tax law practitioner and scholar draws on decades of knowledge-gathering to present a deeply evolved general theory of tax treaty interpretation, thoroughly discussing the starting points and elements of interpretation that should be considered by all stakeholders in the field of international taxation. In the course of his rigorous commentary, the author invokes the established canons that apply to the interpretation of tax treaties, including the Vienna Convention on the Law of Treaties and the OECD and UN Model Conventions. He presents a detailed investigation of the implications for tax treaty interpretation of such topics and issues as the following: essential concepts such as "context" and "qualification"; evolution of international taxation from bilateralism to multilateralism; specific interpretation issues raised by bilateral tax treaties; economic crises as drivers for changes in international taxation rules; the OECD/G-20 BEPS project; digitalization of the economy; pandemic, war, and deglobalization; interpretation of international treaties versus interpretation of domestic laws; and interpretation of double tax conventions in countries that are not OECD members. In the absence of a declaration of international tax principles, this book's in-depth analysis of the theory of interpretation of international tax treaties--given the risks of interpreting treaties with different jurisdictions and different languages--will ensure an appropriate understanding of the current context of international taxation, providing practitioners and policymakers with a fully informed background that will guide the interpretation of any international tax treaty.
Book Synopsis Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries by : United Nations Publications
Download or read book Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries written by United Nations Publications and published by . This book was released on 2014 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.
Book Synopsis Tax Law Design and Drafting, Volume 1 by : Mr.Victor Thuronyi
Download or read book Tax Law Design and Drafting, Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.
Book Synopsis Individuals' Income Under Double Taxation Conventions by : Daniel Vitor Bellan
Download or read book Individuals' Income Under Double Taxation Conventions written by Daniel Vitor Bellan and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 466 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.
Book Synopsis The Improper Use of Tax Treaties:With Particular Reference to the Netherlands and the United States by : Stef Weeghel
Download or read book The Improper Use of Tax Treaties:With Particular Reference to the Netherlands and the United States written by Stef Weeghel and published by Kluwer Law International B.V.. This book was released on 1998-03-27 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: "With particular reference to the Netherlands and the United States."--T.p.
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 Looking Ahead:Inter-National Law in 21st by : D.M. Broekhuijsen
Download or read book Looking Ahead:Inter-National Law in 21st written by D.M. Broekhuijsen and published by Springer. This book was released on 2002-03-21 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt: Many states have set out to develop a multilateral tax instrument with the purpose of amending bilateral treaties in a quick and comprehensive fashion. The recent adoption by as many as a hundred jurisdictions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the OECD Multilateral Instrument) is the most prominent step in this direction. This book provides not only a detailed analysis of the OECD Multilateral Instrument but also discusses in depth the far-reaching implications of the international tax reform currently under way. The author shows how the BEPS Project has merely unveiled the problems related to bilateral tax relationships and articulates initiatives to ensure the sustainability of a multilateral consensus. Drawing on the fields of international law, international relations, and political science, he develops a design strategy, complete with draft clauses, that fundamentally transforms the way states cooperate in the field of international tax, effectively addressing such problems as the following: – the need for collective action; – the problem structure of multilateral tax cooperation; – the relevance of the OECD Model Tax Convention and Commentaries thereon; – the place, position and operation of the OECD Multilateral Instrument; – non-OECD member countries; and – treaty shopping. The principled and pragmatic structural solution presented would allow policymakers to continuously adapt and respond to the rapidly evolving nature of the global economy. The author’s original research and his recommendations for future development of the topic offer deeply informed guidance to policymakers, practitioners and other tax professionals, and academics.
Book Synopsis International Taxation of Income from Services under Double Taxation Conventions by : Marta Castelon
Download or read book International Taxation of Income from Services under Double Taxation Conventions written by Marta Castelon and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 544 pages. Available in PDF, EPUB and Kindle. Book excerpt: The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.
Book Synopsis Issues in International Taxation by :
Download or read book Issues in International Taxation written by and published by . This book was released on 1978 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Impact of Tax Treaties and EU Law on Group Taxation Regimes by : Bruno da Silva
Download or read book The Impact of Tax Treaties and EU Law on Group Taxation Regimes written by Bruno da Silva and published by Kluwer Law International B.V.. This book was released on 2016-07-11 with total page 650 pages. Available in PDF, EPUB and Kindle. Book excerpt: Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities – differences arising from the interaction of different tax systems – and obstacles – distortions created by domestic legislation arising from differences between domestic and cross-border situations – both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: – analysis of the different tax group regimes adopted by different countries; – advantages and disadvantages of a variety of models; – application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; – application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; – uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; – interrelations between tax treaties and EU Law in the context of tax groups; and – per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.
