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Model Double Taxation Convention On Income And On Capital
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Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version 2017 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2017 written by OECD and published by OECD Publishing. This book was released on 2017-12-18 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
Book Synopsis Draft Double Taxation Convention on Income and Capital 1963 by :
Download or read book Draft Double Taxation Convention on Income and Capital 1963 written by and published by . This book was released on 1963 with total page 169 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 1963 report presents the articles on the avoidance of double taxation on income and capital, as agreed upon by the Fiscal Committee. Double taxation is the taxation of a single taxpayer with respect to the same subject matter over the same period in more than one country. This draft aims to inspire further conventions on the elimination of double taxation, a threat to trade and migration. The report includes commentaries on the articles, progress on the elimination of double taxation, and possible future developments.
Book Synopsis Model Tax Convention on Income and on Capital 2017 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2017 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2019-04-25 with total page 2624 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Book Synopsis Model Tax Convention on Income and on Capital 2014 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2014 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2015-10-30 with total page 2289 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014.
Book Synopsis Model Double Taxation Convention on Income and Capital 1977 by : OECD
Download or read book Model Double Taxation Convention on Income and Capital 1977 written by OECD and published by OECD Publishing. This book was released on 1977-10-19 with total page 209 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 1977 report contains the recommendations of the Committee on Fiscal Affairs for the avoidance of double taxation on income and capital. These recommendations result from consultation with member countries, following the 1963 Draft Convention. Double taxation is the taxation of a single ...
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version 2003 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2003 written by OECD and published by OECD Publishing. This book was released on 2003-01-20 with total page 342 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the condensed version of the OECD Model Tax Convention on Income and on Capital, produced in a loose-leaf format to accommodate yearly updates. This fifth edition contains the full text of the Model Tax Convention as it read on 28 January 2003, but without the historical notes.
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version 2008 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2008 written by OECD and published by OECD Publishing. This book was released on 2008-08-31 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Condensed Version of the OECD Model Tax Convention contains the articles and commentaries of the Model Tax Convention as it read on 17 July 2008.
Book Synopsis Introduction to the Law of Double Taxation Conventions by : Michael Lang
Download or read book Introduction to the Law of Double Taxation Conventions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2021-04-01 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version September 1992 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version September 1992 written by OECD and published by OECD Publishing. This book was released on 1992-10-19 with total page 243 pages. Available in PDF, EPUB and Kindle. Book excerpt: Condensed version of the loose-leaf publication "Model tax convention on income and capital", containing the full text of the September 1992 Model Tax Convention, but omitting the historical notes and annexes, which include a detailed list of tax conventions between OECD member countries and the text of the Recommendation of 23 July 1992 from the OECD Council.
Book Synopsis Source Versus Residence by : Michael Lang
Download or read book Source Versus Residence written by Michael Lang and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Book Synopsis Beneficial Ownership in International Tax Law by : Angelika Meindl-Ringler
Download or read book Beneficial Ownership in International Tax Law written by Angelika Meindl-Ringler and published by Kluwer Law International B.V.. This book was released on 2016-06-07 with total page 458 pages. Available in PDF, EPUB and Kindle. Book excerpt: In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits. However, determining beneficial ownership is a complex and often disputed issue, subject to different meanings in different countries. Archival research on its early use in tax treaties and in the developing OECD Model reveals that its meaning has changed dramatically over the decades, leading to new interpretations significantly affecting current tax practice and scholarship. This book, dedicated to establishing how beneficial ownership should ideally be interpreted, compares the use and interpretation of benefi-cial ownership, both current and historical, in a wide range of national jurisdictions as well as the EU, ultimately shedding a clearer light than has heretofore been available on the meaning of the term. In her very thorough analysis of the application of beneficial ownership, the author touches on such aspects as the following: – historical development of the beneficial ownership requirement as used in tax treaties and in the OECD Model Tax Convention on Income and on Capital; – rules of double taxation conventions; – application of the OECD’s Action Plan on Base Erosion and Profit-Shifting (BEPS); – the problem of so-called ‘white income’; – use of the substance-over-form principle; – attribution-of-income rules; and – the role of agents, nominees, and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in a domestic law and treaty context in numerous jurisdictions – with particular emphasis on the United Kingdom, Australia, the United States, and Germany – is a major feature of the presentation. As a thorough guide to determining whether a person claiming tax treaty benefits is the true owner – and which parties are excluded from treaty benefits and to what extent – this book will be of immeasurable value to lawyers, tax authorities, policymakers, and other professionals working with taxable international transactions of any kind.
Book Synopsis Judicial Interpretation of Tax Treaties by : Carlo Garbarino
Download or read book Judicial Interpretation of Tax Treaties written by Carlo Garbarino and published by Edward Elgar Publishing. This book was released on 2016-10-28 with total page 699 pages. Available in PDF, EPUB and Kindle. Book excerpt: Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.
Book Synopsis International Taxation of Trust Income by : Mark Brabazon
Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2019-05-02 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
Book Synopsis U.S. Tax Treaties by : United States. Internal Revenue Service
Download or read book U.S. Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Model Tax Convention on Income and on Capital: Condensed Version 2005 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2005 written by OECD and published by OECD Publishing. This book was released on 2005-11-18 with total page 375 pages. Available in PDF, EPUB and Kindle. Book excerpt: This update of the Condensed Version of the OECD Model Tax Convention contains the full text of the Articles, Commentaries, and Country Positions as they read on 15 July 2005, but without the historical notes, background reports, and list of conventions.
