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Issues In International Taxation Thin Capitalisation Taxation Of Entertainers Artistes And Sportsmen
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Book Synopsis Issues in International Taxation Thin Capitalisation - Taxation of Entertainers, Artistes and Sportsmen by : OECD
Download or read book Issues in International Taxation Thin Capitalisation - Taxation of Entertainers, Artistes and Sportsmen written by OECD and published by OECD Publishing. This book was released on 1987-05-02 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication brings together two reports prepared by the Committee on Fiscal Affairs; "Thin Capitalisation" and "The Taxation of Income Derived from Entertainment, Artistic and Sporting Activities",
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 :76 pages Book Rating :4.:/5 (41 download)
Book Synopsis Thin Capitalisation ; Taxation of Entertainers, Artistes and Sportsmen by : Organisation for Economic Co-operation and Development
Download or read book Thin Capitalisation ; Taxation of Entertainers, Artistes and Sportsmen 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 1987 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the first report the various forms that hidden capitalisation can take are examined, the implications for tax yields and the ways in which countries can use double taxation treaties to deal with these situations. In the second report the problems that arise for tax authorities from entertainment and sporting activities are described and the measures they have taken to counteract non-compliance in this area.
Book Synopsis Taxation of International Performing Artistes by : Dick Molenaar
Download or read book Taxation of International Performing Artistes written by Dick Molenaar and published by IBFD. This book was released on 2005 with total page 439 pages. Available in PDF, EPUB and Kindle. Book excerpt: The special tax rules for performing artistes lead to obstacles. This book considers the problems regarding, for example, the determination of taxable income and the non-deductibility of expenses and tax credits in the country of residence, and gives clear examples of excessive taxation.
Book Synopsis Taxation of Artistes and Sportsmen in International Tax Law by : Walter Loukota
Download or read book Taxation of Artistes and Sportsmen in International Tax Law written by Walter Loukota and published by . This book was released on 2007 with total page 502 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Thin Capitalisation written by and published by . This book was released on 1987 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation Of Artistes And Sportsmen In International Tax Law by : Michael Lang
Download or read book Taxation Of Artistes And Sportsmen In International Tax Law written by Michael Lang and published by . This book was released on 2008-09-01 with total page 504 pages. Available in PDF, EPUB and Kindle. Book excerpt: Some artistes and sportsmen are 'flying birds'. Especially very famous artistes and sportsmen spread their activity - and thus their income-across several countries. Still, normally they do not have a qualified connection - a permanent establishment in the state of performance or a presence fulfilling the criteria of the 183-days rule-to the state of source. Therefore, the OECD introduced a special rule for artistes and sportsmen.Practical experience shows that cross border activities of artistes and sportsmen cause a lot of issues. Issues are caused by the interpretation of the special rule in tax treaties and their interdependence with other treaty provisions. Besides that, artistes and sportsmen are often confronted with discrimination in the state of source. Last but not least, artistic and sportive activities cause specific VAT issues. This volume strives to analyse these issues and to give conclusions based on the interpretation of current international tax law. Furthermore, the authors intend to show how international tax law could be improved where an improvement seems necessary.
Book Synopsis Taxation of Entertainers, Athletes, and Artists by : Lionel S. Sobel
Download or read book Taxation of Entertainers, Athletes, and Artists written by Lionel S. Sobel and published by American Bar Association. This book was released on 2015 with total page 390 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the specialized issues affecting the income taxation of entertainers, athletes, and artists. It considers both domestic and international taxation. It includes numerous examples, calculations, charts and graphs.
Book Synopsis The Taxation of International Entertainers and Athletes:All the World's a Stage by : Daniel Sandler
Download or read book The Taxation of International Entertainers and Athletes:All the World's a Stage written by Daniel Sandler and published by Springer. This book was released on 1995-09-21 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Taxation of International Entertainers and Athletes: All the World's a Stage provides a comprehensive and detailed analysis of the taxation of non-resident entertainers and athletes in seven countries: Australia, Canada, France, Germany, Japan, the United Kingdom and the United States. The book deals with the many sources of income which such individuals can derive, including income from live performances, television appearances, commercials, product endorsements, royalties for record sales or `needle time', and merchandising of concert paraphernalia. The primary focus of the book is income tax, although VAT regimes are also considered. In addition, the book provides in-depth analysis of Article 17 (Artists and Sportsmen) of the OECD Model Tax Treaty, particularly regarding the extensive additions to the Commentary to that Article made in 1992 based on the OECD's 1987 report on the taxation of entertainers and athletes. The book contains a table summarising the tax treaty provisions applicable to personal services income derived by entertainers and athletes in the seven countries reviewed. Two examples (one dealing with a touring pop group and the other with a professional tennis player) are used to illustrate, compare and contrast the manner in which income earned by non-resident entertainers and athletes is treated under domestic income tax and VAT regimes (where applicable) in these countries. Finally, conclusions are drawn, at the domestic and international levels, regarding policy and practical considerations in the effective and efficient taxation of such individuals.
Book Synopsis International Taxation of Artistes & Sportsmen by : Xavier Oberson
Download or read book International Taxation of Artistes & Sportsmen written by Xavier Oberson and published by . This book was released on 2009 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Non-Resident Entertainers by : International Fiscal Association Staff
Download or read book Taxation of Non-Resident Entertainers written by International Fiscal Association Staff and published by Springer. This book was released on 1996-10-23 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proceedings of a seminar held in Cannes, France, in 1995 during the 49th congress of the International Fiscal Association. Survey of the international tax treatment of non-resident entertainers and athletes under both domestic law and tax treaties. Introduction summarizes the main issues including source and characterization of income, loan out companies and definition of entertainers and athletes.
Book Synopsis International Taxation of Sportsmen and Entertainers : Seminar Université de Lausanne by : D. Molenaar
Download or read book International Taxation of Sportsmen and Entertainers : Seminar Université de Lausanne written by D. Molenaar and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The author reports on a seminar about two topics regarding the international taxation of international sportsmen and entertainers, organized by the Tax Policy Center of the University of Lausanne on 22 September 2017. The first topic dealt with current tax policy issues around art. 17 of the OECD Model Convention. The second topic was the taxation of image rights.
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.
Book Synopsis Taxation of Entertainers and Sportspersons Performing Abroad by : Guglielmo Maisto
Download or read book Taxation of Entertainers and Sportspersons Performing Abroad written by Guglielmo Maisto and published by . This book was released on 2016 with total page 600 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxation of Entertainers and Sportspersons Performing Abroad', comprising the proceedings and working documents of an annual seminar held in Milan in November 2015, is a detailed and comprehensive study on the taxation of highly mobile individuals engaged in the artistic and sports sectors. It begins with a comparative analysis of the domestic tax regime of such individuals and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union. 0The book then moves to selected tax treaty issues. In particular, it analyses: (i) the history of article 17 of the OECD Model Tax Convention; (ii) recent developments concerning that article, particularly the 2014 amendments to the Commentary on Article 17 of the OECD Model Convention; (iii) tax treaty issues related to qualification, allocation and apportionment of income derived by entertainers and sportspersons; and (iv) the taxation of income from image rights, sponsorship and advertising.
Book Synopsis BRICS and International Tax Law by : Peter Antony Wilson
Download or read book BRICS and International Tax Law written by Peter Antony Wilson and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.
Book Synopsis International Tax by : Michael Honiball
Download or read book International Tax written by Michael Honiball and published by Siber Ink. This book was released on 2011-03-15 with total page 908 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is not merely a new edition, but a complete and significantly expanded rewrite. It comprises over 900 pages of expert and in-depth exposition of this complex subject that has become so important in the modern global economy. Already established over four previous editions as the pre-eminent work on the subject it is a 'must-own book' for all students and practitioners of tax, whether from a legal, business or accounting perspective. Professor Lynette Olivier and Michael Honiball are without peer in their understanding and clarity in this highly specialised field. Five new chapters have been added on: Taxation of individuals; Taxation of Companies and Dividends; Taxation of Partnerships; Cross-border VAT; and Interpretation of Statutes.
Book Synopsis International Double Taxation of Interest by : Sandra Martinho Fernandes
Download or read book International Double Taxation of Interest written by Sandra Martinho Fernandes and published by . This book was released on 2019 with total page 437 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The International Tax Law Concept of Dividend by : Marjaana Helminen
Download or read book The International Tax Law Concept of Dividend written by Marjaana Helminen and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 306 pages. Available in PDF, EPUB and Kindle. Book excerpt: The distribution of profits between corporations resident in different jurisdictions gives rise to significant tax planning opportunities for multinational enterprises. As cross-border transactions between corporations grow in number and complexity, the question of how a profit distribution is classified for corporate income tax purposes becomes increasingly important, particularly in the context of issues such as double taxation, non-taxation and tax neutrality. This unique and practical work covers the rules determining which transactions may be classified and therefore taxed as dividend income and how classification conflicts may be resolved. The author examines the classification of various inter-corporate transactions, including: and Payments made under dividend-stripping arrangements. and Fictitious profit distributions. and Economic benefits in the context of transfer pricing. and Returns on debt-equity hybrids. and Interest payments in thin capitalization situations and distributions following liquidation. The analysis of each transaction refers to international tax law. Most weight is given to tax treaties and EU tax law. The approaches adopted in different statesand national tax law are covered by a more general analysis. The comprehensive coverage and practical nature of The International Tax Law Concept of Dividend make it an essential acquisition for tax practitioners, researchers and tax libraries worldwide.
