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Report To The Council On The Work Of The Third Session Of The Committee
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Book Synopsis International and Comparative Taxation:Essays in Honour of Klaus Vogel by : Klaus Vogel
Download or read book International and Comparative Taxation:Essays in Honour of Klaus Vogel written by Klaus Vogel and published by Kluwer Law International B.V.. This book was released on 2002-09-03 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of the 16 English language contributions of "Staaten und Steuern (States and Taxes)", the original festschrift to honour Klaus Vogel.
Book Synopsis Permanent Establishment by : Arvid Aage Skaar
Download or read book Permanent Establishment written by Arvid Aage Skaar and published by Kluwer Law International B.V.. This book was released on 2020-06-19 with total page 999 pages. Available in PDF, EPUB and Kindle. Book excerpt: A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Download or read book Publications written by League of Nations and published by . This book was released on 1927 with total page 588 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis "Taxes Covered" by : Patricia Brandstetter
Download or read book "Taxes Covered" written by Patricia Brandstetter and published by IBFD. This book was released on 2011 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ('Taxes covered') of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpetive issues and uncertainties in practical treaty application. This book not only provides in-depth analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of today's tax treaties. The source documents used have rarely found their way into publications before: historical OEEC and OECD Reports and Minutes, originally largely classified as 'restricted' and thus inaccessible to the public for decades, provide an insight into the drafting process of Art. 2 and the discussions of Delegates from various nations on practical implications for treaty application. The book offers a unique perspective on this core treaty provision and aims to provide guidance for determing the 'taxes covered' in any tax treaty"--Page 4 of cover.
Author :League of Nations. International Committee on Intellectual Co-operation Publisher : ISBN 13 : Total Pages :654 pages Book Rating :4.3/5 ( download)
Book Synopsis Report by : League of Nations. International Committee on Intellectual Co-operation
Download or read book Report written by League of Nations. International Committee on Intellectual Co-operation and published by . This book was released on 1922 with total page 654 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Public Affairs Information Service Bulletin by :
Download or read book Public Affairs Information Service Bulletin written by and published by . This book was released on 1923 with total page 454 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis How Fixed Is a Permanent Establishment? by : Jean Schaffner
Download or read book How Fixed Is a Permanent Establishment? written by Jean Schaffner and published by Kluwer Law International B.V.. This book was released on 2013-02-01 with total page 578 pages. Available in PDF, EPUB and Kindle. Book excerpt: Permanent establishment is the key concept for allocating taxation rights in respect of business income, and the question ‘Is there a permanent establishment?’ is a tax treaty issue that advisers, government officials, and courts perennially confront. Based on a ‘fixed link to the ground’, the idea has become progressively more difficult to apply until, at this stage, re-evaluation has become a political necessity. If a permanent establishment may exist in the context of e-commerce, the concept of a geographical presence must be redefined. However, the question remains: Is e-commerce a sufficient reason for challenging the well-established permanent establishment nexus? Drawing on case law, administrative practice, and business decisions in numerous jurisdictions, the author discusses the permanent establishment criteria under conditions of e-commerce and the service economy. He shows that the OECD Model Convention and its commentaries already offer the basis for the evolution of the analysis of the concept, and that the preservation of permanent establishment protects and maintains the level playing field between capital importing and capital exporting economies. He examines in depth such elements as the following: ;the prevalence of commercial coherence over geographic coherence; the role of value-added tax; services permanent establishment; relevant definitions of ‘activity’ and ‘personnel’; multiple permanent establishments; supervision activity and sub-contracting; the differences between civil law and common law concepts of representation; particular treatment of the insurance sector; the ‘force of attraction’ concept; and specific exceptions (e.g., transportation, artists and sportsmen, rental income, agricultural activities, pipelines). Taking into account important distinctions between two model conventions (OECD and UN), as well as pertinent EU directives and the impact of EU law, the author proposes minor amendments to the OECD Model that adapt it to economic reality and current trends in jurisprudence and that can be implemented immediately. An appendix includes Article 5 and its commentaries as they have evolved since 1963, with the successive addenda and deletions. The author’s 20-plus years of experience as a tax lawyer lend the presentation a thoroughly practical aspect. The work addresses in more detail than any other publication the topic of profit allocation to a permanent establishment in the e-commerce world, an issue which is evolving rapidly in the current economic environment. Tax advisors, lawyers, and interested academics and policymakers will benefit from the book’s clear analysis of the conditions under which a permanent establishment not only should be preserved, but also how it is likely to be adapted in the future.
Book Synopsis 'Like Products' in International Trade Law by : Won-Mog Choi
Download or read book 'Like Products' in International Trade Law written by Won-Mog Choi and published by Columbia University Press. This book was released on 2003 with total page 292 pages. Available in PDF, EPUB and Kindle. Book excerpt: The obligations of international trade law hinge upon the question of what constitute 'like products'. This book seeks to develop consistent principles and an effective definition for this central issue of world trade law.
Book Synopsis The United Nations in Global Tax Coordination by : Nikki J. Teo
Download or read book The United Nations in Global Tax Coordination written by Nikki J. Teo and published by Cambridge University Press. This book was released on 2023-03-23 with total page 493 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book reveals the missing international tax history of how the UN was ousted from global international tax policy making by developed countries.
Book Synopsis Records of the Proceedings and Printed Papers of the Parliament by : Australia. Parliament
Download or read book Records of the Proceedings and Printed Papers of the Parliament written by Australia. Parliament and published by . This book was released on 1926 with total page 2588 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Annual Report of the Health Organisation by : Health Organisation
Download or read book Annual Report of the Health Organisation written by Health Organisation and published by . This book was released on 1926 with total page 350 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Index to the Correspondence of the Foreign Office by : Great Britain. Foreign Office
Download or read book Index to the Correspondence of the Foreign Office written by Great Britain. Foreign Office and published by . This book was released on 1939 with total page 720 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Records of the ... Assembly by : League of Nations. Assembly
Download or read book Records of the ... Assembly written by League of Nations. Assembly and published by . This book was released on 1924 with total page 1530 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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.
Book Synopsis The Universal Declaration of Human Rights by : Johannes Morsink
Download or read book The Universal Declaration of Human Rights written by Johannes Morsink and published by University of Pennsylvania Press. This book was released on 1999 with total page 400 pages. Available in PDF, EPUB and Kindle. Book excerpt: A splendid volume . . . fused with political and philosophical insight into the fundamental concepts underlying the Declaration.--American Journal of International Law
Author :Wisconsin. Legislature. Legislative Council Publisher :Legislative Reference Bureau ISBN 13 : Total Pages :134 pages Book Rating :4.:/5 (89 download)
Book Synopsis Report of the Wisconsin Legislative Council, Submitted to the Governor and the Legislature, January, 1953 by : Wisconsin. Legislature. Legislative Council
Download or read book Report of the Wisconsin Legislative Council, Submitted to the Governor and the Legislature, January, 1953 written by Wisconsin. Legislature. Legislative Council and published by Legislative Reference Bureau. This book was released on 1953 with total page 134 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book League of Nations Publications written by and published by . This book was released on 1928 with total page 576 pages. Available in PDF, EPUB and Kindle. Book excerpt:
