Multilateral Tax Treaties

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A Multilateral Convention for Tax

Author : Sergio André Rocha
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041194290
Total Pages : 401 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis A Multilateral Convention for Tax by : Sergio André Rocha

Download or read book A Multilateral Convention for Tax written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2021-11-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.

Schwarz on Tax Treaties

Author : Jonathan Schwarz
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403526319
Total Pages : 870 pages
Book Rating : 4.4/5 (35 download)

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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’.

Multilateral Tax Treaties

Author : Helmut Loukota
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041107045
Total Pages : 266 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Multilateral Tax Treaties by : Helmut Loukota

Download or read book Multilateral Tax Treaties written by Helmut Loukota and published by Kluwer Law International B.V.. This book was released on 1998-04-22 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is a result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed analysis of the arguments for and against the conclusion of a multilateral tax treaty, and of the various European law issues that arise in this context.

The OECD Multilateral Instrument for Tax Treaties

Author : Michael Lang
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041189165
Total Pages : 296 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis The OECD Multilateral Instrument for Tax Treaties by : Michael Lang

Download or read book The OECD Multilateral Instrument for Tax Treaties written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 296 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Instrument (MLI) proposed in OECD BEPS Action 15 will lead to the modification of numerous tax treaties. As tax treaties can have different wording, terminology and structure, a great challenge is to find a proper way to accomplish their modification without distorting the underlying framework or triggering undesirable effects. This book analyses the MLI, which was signed by over seventy jurisdictions on 7 June 2017. The topics covered include: • the procedural mechanisms on how the new measures to prevent base erosion and profit shifting (BEPS) will interact with and complement existing tax treaties; • the scope of the MLI in order to ascertain which tax treaties and taxes are covered; • the interpretation of terms used in the MLI and the relationship between the languages used in the MLI and in the particular tax treaties; • the implementation of the minimum standard through the MLI, as well as how states can exercise various options offered by the MLI and reserve the right not to apply certain provisions of the MLI; • the legal consequences of the exercise of options and reservations for the other states; • the notification procedure through which states declare their choices; and • the possibilities and procedure for withdrawal from the obligations entered into upon signing the MLI. Finally, the book discusses whether the mechanism of the MLI can serve as a role model for future changes to the OECD Model Convention. The book incorporates the analyses of leading scholars and practitioners dealing with international tax matters. Critical insights are offered for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.

Double Taxation and the League of Nations

Author : Sunita Jogarajan
Publisher : Cambridge University Press
ISBN 13 : 1108381820
Total Pages : 425 pages
Book Rating : 4.1/5 (83 download)

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Book Synopsis Double Taxation and the League of Nations by : Sunita Jogarajan

Download or read book Double Taxation and the League of Nations written by Sunita Jogarajan and published by Cambridge University Press. This book was released on 2018-05-10 with total page 425 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.

International Tax Policy and Double Tax Treaties

Author : Kevin Holmes
Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)

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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.

A Multilateral Instrument for Updating the Tax Treaty Network

Author : Nathalie Bravo
Publisher :
ISBN 13 : 9789087225919
Total Pages : 339 pages
Book Rating : 4.2/5 (259 download)

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Book Synopsis A Multilateral Instrument for Updating the Tax Treaty Network by : Nathalie Bravo

Download or read book A Multilateral Instrument for Updating the Tax Treaty Network written by Nathalie Bravo and published by . This book was released on 2020 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: A precise and in-depth analysis of the Multilateral Instrument and of how it impacts the tax treaty network by implementing the treaty-related BEPS measures.

Looking Ahead:Inter-National Law in 21st

Author : D.M. Broekhuijsen
Publisher : Springer
ISBN 13 : 9789041198723
Total Pages : 298 pages
Book Rating : 4.1/5 (987 download)

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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.

Model Tax Convention on Income and on Capital: Condensed Version 2017

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264287957
Total Pages : 656 pages
Book Rating : 4.2/5 (642 download)

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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 656 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...

MLI Made Easy

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403532610
Total Pages : 352 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis MLI Made Easy by : Kuldeep Sharma

Download or read book MLI Made Easy written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) provides an innovative approach to enable countries to swiftly modify their bilateral tax treaties in order to implement measures developed in the course of the Base Erosion and Profit Shifting (BEPS) Project. MLI, the first successfully concluded multilateral tax treaty, provides jurisdictions with the tools they need to ensure that profits are taxed where economic activities generating the profits are performed, while at the same time giving businesses greater certainty. MLI Made Easy makes it easier to get a complete grasp of this swift but complex modification process of tax treaties. This first and only self-contained book offers an unmatched article-by-article discussion of the MLI with an abundance of practical examples, diagrams, and flowcharts to make the information easier to understand and apply. Focusing on measures to combat tax evasion and abuse of tax treaties arising due to artificial avoidance of a permanent establishment status, hybrid mismatch arrangements, and other aspects of taxation, the book includes an in-depth discussion of the following and more: how specific gaps in existing bilateral tax treaties are addressed by the MLI; positions taken by selected jurisdictions and their impact on treaties; compatibility clauses, notification clauses, opting-in mechanisms, alternative provisions, and reservations; experiences in the course of implementation of the MLI; misconceptions and lingering doubts in respect of various substantive and procedural provisions of the MLI; interaction between the principal purpose test and simplified limitation on benefits; improving dispute resolution; and meaning of the phrases ‘on or after’, ‘other taxes’, and interpretational issues in entry into effect provisions. Adopted by a majority of jurisdictions worldwide, MLI preserves the tax sovereignty of its Parties and has been successful in overcoming barriers to the conclusion of a worldwide multilateral tax treaty. Because this easy-to-use book immensely facilitates understanding and application of the treaty measures developed in the course of the BEPS Project, it will be of immeasurable use to practitioners and other professionals engaging in international taxation, as well as to taxation authorities and interested academics in any part of the world.

A Multilateral Tax Treaty

Author : Dirk M. Broekhuijsen
Publisher :
ISBN 13 : 9789041198488
Total Pages : 298 pages
Book Rating : 4.1/5 (984 download)

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Book Synopsis A Multilateral Tax Treaty by : Dirk M. Broekhuijsen

Download or read book A Multilateral Tax Treaty written by Dirk M. Broekhuijsen and published by . This book was released on 2018-03 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.

The Nordic Multilateral Tax Treaty as a Model for a Multilateral EU Tax Treaty

Author : Marjaana Helminen
Publisher :
ISBN 13 : 9789087222222
Total Pages : pages
Book Rating : 4.2/5 (222 download)

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Book Synopsis The Nordic Multilateral Tax Treaty as a Model for a Multilateral EU Tax Treaty by : Marjaana Helminen

Download or read book The Nordic Multilateral Tax Treaty as a Model for a Multilateral EU Tax Treaty written by Marjaana Helminen and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Permanent Establishments

Author : Ekkehart Reimer
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041190759
Total Pages : 850 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Permanent Establishments by : Ekkehart Reimer

Download or read book Permanent Establishments written by Ekkehart Reimer and published by Kluwer Law International B.V.. This book was released on 2018-06-07 with total page 850 pages. Available in PDF, EPUB and Kindle. Book excerpt: Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.

Tax Treaties: Building Bridges between Law and Economics

Author :
Publisher : IBFD
ISBN 13 : 9087221185
Total Pages : 679 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Tax Treaties: Building Bridges between Law and Economics by :

Download or read book Tax Treaties: Building Bridges between Law and Economics written by and published by IBFD. This book was released on 2010 with total page 679 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this book experts from the field of economics take a different view of tax treaty issues than experts from the field of law. In order to encourage the much needed communication between these two groups, a cross-disciplinary conference was held to discuss selected tax treaty issues from both a legal and economic perspective. Twenty-five conference papers on eight topics were prepared by lawyers and economists. The papers on legal issues were presented and discussed by economists, and vice versa. The interdisciplinary focus of the conference not only allowed an exchange of knowledge between two groups who think differently about similar issues, but also made it possible to better grasp the impact of the thinking of one group on the areas of interest to the other group. The outcome of the conference is reflected in this book. By showing the legal and the economic approaches to an issue, this book improves the general understanding of the two disciplines and demonstrates how the decisions in one discipline may influence the other discipline and its concepts. Twenty-two contributions are included, written by the most distinguished academics, practitioners and representatives of several international tax administrations and both tax and economic institutions.

Introduction to the Law of Double Taxation Conventions

Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 3709408628
Total Pages : 266 pages
Book Rating : 4.7/5 (94 download)

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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.

The Effect of Treaties on Foreign Direct Investment

Author : Karl P Sauvant
Publisher : Oxford University Press
ISBN 13 : 0199745188
Total Pages : 800 pages
Book Rating : 4.1/5 (997 download)

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Book Synopsis The Effect of Treaties on Foreign Direct Investment by : Karl P Sauvant

Download or read book The Effect of Treaties on Foreign Direct Investment written by Karl P Sauvant and published by Oxford University Press. This book was released on 2009-03-27 with total page 800 pages. Available in PDF, EPUB and Kindle. Book excerpt: Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.

Interpretation and Application of Tax Treaties in North America

Author : Juan Angel Becerra
Publisher : IBFD
ISBN 13 : 9087220197
Total Pages : 299 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis Interpretation and Application of Tax Treaties in North America by : Juan Angel Becerra

Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.