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Author : Michael Lang
Publisher :
ISBN 13 : 9789087225070
Total Pages : pages
Book Rating : 4.2/5 (25 download)
Download or read book Tax Treaty Entitlement written by Michael Lang and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Desiree Auer
Publisher : Linde Verlag GmbH
ISBN 13 : 3709411602
Total Pages : 496 pages
Book Rating : 4.7/5 (94 download)
Download or read book Access to Treaty Benefits written by Desiree Auer and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.
Author : Joanna Wheeler
Publisher : IBFD
ISBN 13 : 9087221231
Total Pages : 449 pages
Book Rating : 4.0/5 (872 download)
Download or read book The Missing Keystone of Income Tax Treaties written by Joanna Wheeler and published by IBFD. This book was released on 2012 with total page 449 pages. Available in PDF, EPUB and Kindle. Book excerpt: Le site d'IBFD indique : "This thesis reveals a fundamental flaw in the OECD Model, namely that it pays no attention to the person who is liable to tax in respect of the income for which treaty benefits are claimed. This "missing keystone" causes two major problems of interpretation. One problem arises if the contracting states attribute the income to different persons; the myriad ways in which such a conflict can occur is illustrated by an extensive comparison of the domestic law of the Netherlands and the United Kingdom in this respect. This missing keystone also causes a disconnection between the two principal conditions for treaty entitlement. The treaty residence of the claimant is based on a general liability to tax in a contracting state, whereas the distributive articles focus on the ownership of the income. Interpretation problems arise if domestic law imposes a tax liability on a person who is not the owner of the income, for example under anti-avoidance legislation or a corporate group regime. In order to eliminate this fundamental flaw, the thesis proposes a "new approach" in which the criterion for treaty entitlement is liability to tax on the income, backed up by substantial connections between the income and the treaty claimant and between the treaty claimant and the residence state. The new approach is tested in various situations, many of them decided cases, and proves to give appropriate policy results while respecting the tax sovereignty of states. The thesis includes a proposal for a re-draft of the OECD Model on this basis."
Author : MICHAEL. LANG
Publisher :
ISBN 13 : 9789087225056
Total Pages : pages
Book Rating : 4.2/5 (25 download)
Download or read book TAX TREATY ENTITLEMENT. written by MICHAEL. LANG and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :
Publisher : DIANE Publishing
ISBN 13 : 9781422321157
Total Pages : 94 pages
Book Rating : 4.3/5 (211 download)
Download or read book Explanation of proposed protocol to the income tax treaty between the United States and Denmark written by and published by DIANE Publishing. This book was released on 2007 with total page 94 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Kingdom of Denmark written by and published by . This book was released on 1999 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :
Publisher : DIANE Publishing
ISBN 13 : 9781422321140
Total Pages : 106 pages
Book Rating : 4.3/5 (211 download)
Download or read book Explanation of proposed income tax treaty between the United States and Belgium written by and published by DIANE Publishing. This book was released on 2007 with total page 106 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : United States
Publisher : Springer
ISBN 13 :
Total Pages : 678 pages
Book Rating : 4.F/5 ( download)
Download or read book United States Tax Treaties written by United States and published by Springer. This book was released on 1991-02-05 with total page 678 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.
Author : Richard L. Doernberg
Publisher :
ISBN 13 :
Total Pages : 444 pages
Book Rating : 4.:/5 (327 download)
Download or read book U.S. Income Tax Treaties written by Richard L. Doernberg and published by . This book was released on 1999 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: Text originally prepared for a class. Includes course outline, assignments and supporting materials.
Author : Jianwen Liu
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041142320
Total Pages : 320 pages
Book Rating : 4.0/5 (411 download)
Download or read book Europe-China Tax Treaties written by Jianwen Liu and published by Kluwer Law International B.V.. This book was released on 2010-05-28 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book is the result of a joint research project on the tax treaties concluded between the People’s Republic of China and European countries. Each chapter carefully analyses the extent to which Chinese tax treaties follow the OECD Model Tax Convention on Income and Capital and the UN Income and Capital Model Convention. The focus is on the different policy decisions underlying the various provisions. Additionally, the contributions analyse the extent to which Chinese tax treaty policy differs with respect to EU and non-EU Member States. They also highlight relevant policy changes over time. The fact that each contribution is the product of the collaboration between European and Chinese researchers and includes the results of the International Conference on Europe - China Tax Treaties Research, held in March 2009 in Beijing, serves to enrich its analysis. Among the topics covered are the following: • Treaty Entitlement (Articles 1, 4 and 24 OECD Model) • Business Profits (Articles 5, 6, 7, 8, 9, and 14 OECD Model) • Passive Income (Articles 10, 11, and 12 OECD Model) • Capital Gains (Article 13 OECD Model) • Employment Income (Articles 15, 16, 18, 19, and 20 OECD Model) • Artistes and Sportsmen (Article 17 OECD Model) • Methods to Avoid Double Taxation (Article 23 OECD Model) • Non-Discrimination (Article 24 OECD Model) • Mutual Agreement, Exchange of Information and Mutual Assistance in the Collection of Taxes (Articles 25, 26 and 27 OECD Model)
Author : Michael Lang
Publisher : Linde Verlag GmbH
ISBN 13 : 3709408628
Total Pages : 266 pages
Book Rating : 4.7/5 (94 download)
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.
Author : United States. Congress. Joint Committee on Taxation
Publisher :
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.:/5 (327 download)
Download or read book Explanation of Proposed Protocol to the Income Tax Treaty Between the United States and Australia written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 2003 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight
Publisher :
ISBN 13 :
Total Pages : 182 pages
Book Rating : 4.0/5 (9 download)
Download or read book Income Tax Treaties written by United States. Congress. House. Committee on Ways and Means. Subcommittee on Oversight and published by . This book was released on 1980 with total page 182 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author :
Publisher :
ISBN 13 :
Total Pages : 70 pages
Book Rating : 4.:/5 (327 download)
Download or read book Explanation of Proposed Income Tax Treaty and Proposed Protocol Between the United States and the Swiss Confederation written by and published by . This book was released on 1997 with total page 70 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Canada-U.S. Tax Treaty written by and published by . This book was released on 1981 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Author : Karl L. Kellar
Publisher :
ISBN 13 : 9781633593176
Total Pages : pages
Book Rating : 4.5/5 (931 download)
Download or read book U.S. Income Tax Treaties written by Karl L. Kellar and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: ... covers the benefits granted under a bilateral income tax treaty by one of the parties to the treaty to its own residents and citizens. Among these benefits are: (1) elimination or reduction of the tax liabilities of a country's residents and citizens in order to provide relief from double taxation that would otherwise arise from the other country's imposition of tax on the same items of income, with a focus on treaty and Code resourcing provisions; (2) elimination or reduction of the tax liabilities of a country's residents and citizens with respect to specific types of income for which the treaty assigns primary taxing jurisdiction to the other country (e.g., compensation for government employment, benefits from and contributions to pensions and retirement plans, and alimony and child support); (3) correlative adjustments in the case of transfer pricing adjustments involving associated enterprises; (4) the Mutual Agreement Procedure, under which a person may invoke a procedure for bilateral negotiations to relieve double taxation not otherwise resolved by the treaty's provisions; and (5) non-discrimination, under which Contracting States cannot discriminate against each other's nationals or residents in matters of taxation.
Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 28 pages
Book Rating : 4.3/5 (126 download)
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:
