Read Books Online and Download eBooks, EPub, PDF, Mobi, Kindle, Text Full Free.
Non Discrimination Rules In International Taxation
Download Non Discrimination Rules In International Taxation full books in PDF, epub, and Kindle. Read online Non Discrimination Rules In International Taxation ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!
Book Synopsis The principle of non-discrimination in international and European tax law by : Niels Bammens
Download or read book The principle of non-discrimination in international and European tax law written by Niels Bammens and published by IBFD. This book was released on 2012 with total page 1151 pages. Available in PDF, EPUB and Kindle. Book excerpt: The principle of non-discrimination plays a vital role in international and European tax law. This dissertation analyses the interpretation given to that principle in tax treaty practice and in the direct tax case law of the Court of Justice of the European Union (ECJ) on the fundamental freedoms. The objective of this analysis is twofold: to give a clear and thorough overview of both standards and to determine whether they share a common, underlying principle of non-discrimination. In order to achieve these objectives, a comprehensive selection of case law is discussed from the perspective of the two constitutive elements of discrimination, comparability and the existence of different treatment. Moreover, attention is drawn to the question whether a domestic measure that is found to be discriminatory may nevertheless be justified on the basis of reasons of public interest. Finally, the possible interplay between both standards is addressed.
Book Synopsis Non-discrimination rules in international taxation by : Willem F. G. Wijnen
Download or read book Non-discrimination rules in international taxation written by Willem F. G. Wijnen and published by . This book was released on 1992 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Non-discrimination in Tax Treaty Law and World Trade Law by : Kasper Dziurdź
Download or read book Non-discrimination in Tax Treaty Law and World Trade Law written by Kasper Dziurdź and published by Kluwer Law International B.V.. This book was released on 2019-07-23 with total page 715 pages. Available in PDF, EPUB and Kindle. Book excerpt: Non-discrimination is a central obligation under both tax treaty and trade law. However, in seeking to strike a balance between national and international interests, its application differs in the two areas of practice. This deeply researched and authoritative work, which explains the policy issues and how non-discrimination analysis works, provides a comprehensive review of non-discrimination rules in WTO and tax treaty law, combining a critical commentary on case law with proposals for an innovative concept for solving cases of discrimination in tax treaty law. Among the practical issues affecting non-discrimination examined in detail are the following: implications that can be drawn from the concepts of non-discrimination under WTO law and Article 24 of the OECD Model; direct and indirect discrimination and analysis of comparability in WTO law and tax treaty law; the MFN and NT rules under the GATT and GATS; the meaning of ‘likeness’ and ‘less favourable treatment’; claiming non-discriminatory tax treatment before tax administrations and courts under a tax treaty; justification of measures against harmful tax competition, low taxation and hybrid mismatch arrangements; thin capitalisation rules, progressive tax rates, foreign losses, group taxation and relief from juridical and economic double taxation under Article 24 of the OECD Model; and integrating a justification defence into any stage of a non-discrimination analysis. The author establishes to what extent formal, substantive and subjective approaches may be applied in a non-discrimination analysis, providing the reasons for the approaches taken. A two-step comparability procedure is applied to selected cases of potential tax discrimination, demonstrating how policy arguments can be addressed under Article 24 of the OECD Model. Drawing on over a half-century of case law in both areas of practice, this comprehensive study of the non-discrimination rules under WTO law and international tax law will be invaluable in systematically solving cases of tax discrimination under Article 24 of the OECD Model and putting forward arguments at any stage of a WTO analysis. Policymakers will benefit from the author’s clear explanation of how national law should comply with international obligations. Also, taxpayers’ advisers will proceed confidently in claims of tax treaty discrimination, and academics will discover an incomparable overview and analysis of anti-discrimination rules in international trade law and double taxation conventions.
Book Synopsis Nondiscrimination in International Tax Law by : Kees van Raad
Download or read book Nondiscrimination in International Tax Law written by Kees van Raad and published by . This book was released on 1986 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Nondiscrimination in International Tax Law by : Kees van Raad
Download or read book Nondiscrimination in International Tax Law written by Kees van Raad and published by Springer. This book was released on 1986-06-10 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Nondiscrimination in International Tax Law provides a discussion of the various restrictions which States must observe in taxing foreign persons. The author analyzes in-depth the restrictions imposed by the nondiscrimination clauses of Article 24 of the 1963 and 1977 OECD Model Double Taxation Conventions. In addition, attention is given to the deviations from these model clauses in the tax treaties concluded by the Netherlands and by the United States. The book includes a discussion of the tax-orientated national treatment and most favored nation clauses in Dutch and US commercial treaties. As the existing treaty nondiscrimination clauses suffer from a lack of consistency and underlying philosophy, in the final chapter an attempt is made to develop a comprehensive approach to equality in tax treatment of foreign persons. This title is published as number 6 in the Series on International Taxation
Book Synopsis Non-discrimination Rules in International Taxation; Interpretation of Double Taxation Conventions by :
Download or read book Non-discrimination Rules in International Taxation; Interpretation of Double Taxation Conventions written by and published by . This book was released on 1993 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Nondiscrimination in International Tax Law by :
Download or read book Nondiscrimination in International Tax Law written by and published by . This book was released on 1986 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Non-Discrimination in Tax Treaties by : Pasquale Pistone
Download or read book Non-Discrimination in Tax Treaties written by Pasquale Pistone and published by . This book was released on 2016 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recoge: 1: Nationality Non-Discrimination and Article 24 OECD Model: Perennial Issues, Recent Trends and New Approaches - 2: Non-Discrimination on the Basis of Nationality in IIAs: A Latin American Tax Perspective - 3: Interest Deduction Limitations: When To Apply Articles 9 and 24(4) of the OECD Model? - 4: Revisiting the Application of the Capital Ownership Non-Discrimination Provision in Tax Treaties - 5: Non-Discrimination in Tax Treaties – Art. 24(4) and (5) OECD MC: A Russian Approach to Tax Treaty Interpretation - 6: Non-Discrimination and Harmful Tax Competition under WTO Law and Article 24 of the OECD Model - 7: Non-Discrimination: Can the EU Learn from the OECD Model Convention and Vice Versa? - 8: Non-Discrimination à la Cour: The ECJ’s (Lack of) Comparability Analysis in Direct Tax Cases - 9: Discriminatory Taxation and the European Convention on Human Rights.
Book Synopsis IFA Cahiers 1993 - Vol. 78b. Non-discrimination rules in international taxation by :
Download or read book IFA Cahiers 1993 - Vol. 78b. Non-discrimination rules in international taxation written by and published by . This book was released on with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Principle of Non-discrimination in International and European Tax Law by : Niels Bammens
Download or read book The Principle of Non-discrimination in International and European Tax Law written by Niels Bammens and published by . This book was released on 2011 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Non-discrimination in European and Tax Treaty Law by : Kasper Dziurdź
Download or read book Non-discrimination in European and Tax Treaty Law written by Kasper Dziurdź and published by . This book was released on 2015 with total page 601 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Time and Tax: Issues in International, EU, and Constitutional Law by : Werner Haslehner
Download or read book Time and Tax: Issues in International, EU, and Constitutional Law written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: Time is a crucial dimension in the application of any law. In tax law, however, where an environment characterized by rapid change on the national, European, and international levels complicates the provision of accurate legal advice, timing is particularly sensitive. This book is the first to analyse the relationship between time and three key areas of tax: treaties, EU law, and constitutional law issues, such as legal certainty and individual rights. Among the numerous timing issues arising out of applying tax rules, the book addresses the following: – time limits within which relief must be requested; – statutes of limitation for claiming a tax refund; – transitional issues relating to changes in tax treaties; – attribution of profits and expenses to a moving or closed-down business; – effect of tax-related CJEU decisions and EU directives; – compliance of exit tax regimes with free movement; – limits of retroactivity under principles protected by the EU Charter and the ECHR; and – conflict between efficiency of taxation and individual rights. Derived from a recent conference organized by the prestigious ATOZ Chair for European and International Taxation at the University of Luxembourg, the book brings together contributions from leading tax experts from various areas of tax practice, academia, and the judiciary. Among other issues, the book notably expands on how economic theory can inform a constitutional analysis of the timing of taxation. There is no other work that concentrates so usefully on the difficulties associated with applying tax rules – whether arising from treaties, jurisprudence, or policy – to changing circumstances over time. This book will quickly prove itself to be an indispensable resource for European tax lawyers, policymakers, company counsels, and academics.
Book Synopsis Non-discrimination at the crossroads of international taxation by :
Download or read book Non-discrimination at the crossroads of international taxation written by and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Non-discrimination and Trade in Services by : Catherine A. Brown
Download or read book Non-discrimination and Trade in Services written by Catherine A. Brown and published by Springer. This book was released on 2018-12-12 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book argues that the proliferation of global trade and the increasing power of free trade arrangements leave income taxes as one of the few remaining measures that can potentially be used for protectionist purposes. It analyzes the interaction between the non-discrimination principles in tax treaties and trade-related agreements including multilateral (WTO), regional (NAFTA, AANZTA) and bilateral free trade agreements. The absence of a non-discrimination obligation with respect to tax measures that apply to non-resident service providers and to non-resident services may, therefore, significantly undermine trade obligations. The book clearly reveals how these tax barriers to trade may unfairly or unnecessarily restrict trade in services, and puts forward a new, more effective non-discrimination obligation in tax matters to be included in tax treaties, one that would more closely parallel the non-discrimination obligations in trade agreements. The book examines the concept of non-discrimination in tax matters from several perspectives, specifically a North American and Australian perspective, as well as a perspective based on EU (and UK) law, focusing on the interaction between these legal systems, bilateral tax treaties, regional trade agreements and, where relevant, the General Agreement on Trade in Services (GATS). The book explores the possibility of a reciprocal influence between tax treaties and trade agreements, and poses the question as to whether tax treaties might do more in providing a non-discrimination principle in the cross-border trade in services./div
Book Synopsis Non-discrimination at the Crossroads of International Taxation by :
Download or read book Non-discrimination at the Crossroads of International Taxation written by and published by . This book was released on 2008 with total page 688 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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
Book Synopsis WTO and Direct Taxation by : Michael Lang
Download or read book WTO and Direct Taxation written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2005-01-01 with total page 776 pages. Available in PDF, EPUB and Kindle. Book excerpt: WTO Law and Direct Taxation are linked in numerous ways. The WTO Agreements, thereof especially the GATT and GATS Agreements, contain several explicit provisions on the subject of direct taxes or even on its delimitation from Tax Treaty Law. To some extent, the scope of application of WTO Law has been broadened by case law to comprise also direct taxes. This entails overlappings particularly with regard to the law of subsidies, prohibitions of discrimination, and most-favoured-nation obligations. This book highlights increasingly relevant interdependencies between WTO Law and Direct Taxation from the viewpoint of 21 States. Special emphasis is placed on the conformity of national taxes on profits with WTO Law as well as on specifics of interpretation in several Member States. 21 National Reports from nearly all EU countries as well as Colombia, Israel, New Zealand, Norway and the USA dealt with this topic and were compiled and published in this volume. Additionally, a General Report prepared by Servatius van Thiel summarises the results of the National Reports. Moreover, experts in this field joining the Conference among them Reuven Avi-Yonah, Michael Lennard and Raymond Luja have volunteered contributions dealing with specific problems of WTO and Direct Taxation.
