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The Impact Of The Oecd And Un Model Conventions On Bilateral Tax Treaties
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Book Synopsis The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties by : Michael Lang
Download or read book The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties written by Michael Lang and published by Cambridge University Press. This book was released on 2012-05-17 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions from five continents and empirically ascertains the impact of the UN and OECD Model Tax Conventions on bilateral tax treaties. It therefore fills a major gap in the international tax literature, which has so far either studied the sole Model Tax Conventions or focused on bilateral treaties in the context of the tax treaty policy of single countries, and sets the pace for a new methodology in the analysis and interpretation of tax treaties. A general report outlines the key points of the analysis, highlights current trends and predicts future developments of multilateralism and global tax law. This is an essential resource for academics, tax authorities and international tax practitioners who find textbooks based on Model Tax Conventions insufficient.
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 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 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 Addressing Base Erosion and Profit Shifting by : OECD
Download or read book Addressing Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-02-12 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
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 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 Tax Treaties and Domestic Law by : Guglielmo Maisto
Download or read book Tax Treaties and Domestic Law written by Guglielmo Maisto and published by IBFD. This book was released on 2006 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Book Synopsis Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions, Second Edition by : OECD
Download or read book Implementing the Tax Transparency Standards A Handbook for Assessors and Jurisdictions, Second Edition written by OECD and published by OECD Publishing. This book was released on 2011-06-27 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: This handbook provides guidance for the assessment teams and the reviewed jurisdictions that are participating in the Global Forum on Transparency and Exchange of Information for Tax Purposes (the “Global Forum”) peer reviews and non-member reviews.
Author :United Nations Conference on Trade and Development. Programme on Transnational Corporations Publisher :New York : United Nations ISBN 13 : Total Pages :744 pages Book Rating :4.3/5 (91 download)
Book Synopsis Sociétés Transnationales by : United Nations Conference on Trade and Development. Programme on Transnational Corporations
Download or read book Sociétés Transnationales written by United Nations Conference on Trade and Development. Programme on Transnational Corporations and published by New York : United Nations. This book was released on 1993 with total page 744 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis International Commercial Tax by : Peter Harris
Download or read book International Commercial Tax written by Peter Harris and published by Cambridge University Press. This book was released on 2010-07-22 with total page 520 pages. Available in PDF, EPUB and Kindle. Book excerpt: Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.
Book Synopsis Tax Treaty Interpretation by : Richard Xenophon Resch
Download or read book Tax Treaty Interpretation written by Richard Xenophon Resch and published by Tredition Gmbh. This book was released on 2020-05-05 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study clarifies the meaning and application of Article 3(2) of the OECD Model Tax Convention on Income and on Capital. It maps the entire historical debate on the provision, illuminates flawed assumptions and misunderstandings in its course, and outlines how these continue to fuel the current controversies. In addition, it provides a comprehensive analysis of German case law concerning the interpretation of tax treaties and examines the extent to which the German Federal Fiscal Court has been influenced by views developed in doctrine. Finally, it clarifies the relationship between Article 3(2) and the rules on treaty interpretation codified in the Vienna Convention on the Law of Treaties, the meaning of 'context', and how the condition 'unless the context otherwise requires' is to be applied. Thereby, an approach is submitted that is firmly based on public international law principles and transcends the current controversies into a holistic synthesis.
Book Synopsis Klaus Vogel on Double Taxation Conventions by : Klaus Vogel
Download or read book Klaus Vogel on Double Taxation Conventions written by Klaus Vogel and published by Springer. This book was released on 1997 with total page 1736 pages. Available in PDF, EPUB and Kindle. Book excerpt: Full Title: Klaus Vogel on Double Taxation Conventions, Third Edition, A Commentary to the OECD, UN and U.S. Model Conventions for the Avoidance of Double Taxation of Income and Capital, With Particular Reference to German Treaty Practice A Commentary to the OECD, UN and U.S. Model Conventions for the Avoidance of Double Taxation of Income and Capital, With Particular Reference to German Treaty Practice. Double taxation conventions (DTCs) raise a plethora of interpretational questions for the practitioner and student of tax law. This book provides the answers. An encyclopedic treatise on DTCs, Klaus Vogel on Double Taxation Conventions is a guide to all legal issues DTCs raise and includes information on worldwide case law and commentators' views. The OECD Model Convention serves as the organisational basis for this work. Each chapter focuses on one article of the Convention and provides: the wording of the article and that of the respective articles of the UN and US Models, the official Commentary by OECD, and an extensive discussion by the authors of the legal problems involved. In addition, Klaus Vogel on Double Taxation Conventions offers an account of all German tax treaties, how they differ from the model provisions, and the potential practical impact of such differences. The first two editions have been used by lawyers, tax advisers, and scholars all over the world. Courts in Canada, Germany, South Africa, and the Netherlands have cited them as authority. This revised edition includes the most recent OECD Model revisions and all recent case law and relevant literature. The authors have rethought many of the problems discussed, further improved their argument, and amended their views where they have been convinced by opponents.
Book Synopsis Current Tax Treaty Issues by : Guglielmo Maisto
Download or read book Current Tax Treaty Issues written by Guglielmo Maisto and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis BRICS and the Emergence of International Tax Coordination by :
Download or read book BRICS and the Emergence of International Tax Coordination written by and published by . This book was released on 2017 with total page 440 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the impact of shifting economic powers on the evolution of the international tax regime and on tax treaties that follow the OECD Model. It examines from a wide variety of perspectives and views, considering substantive tax technical, institutional and political aspects. A group of experts contributed to form this discourse that focuses on, yet is not limited to, Brazil, Russia, India, China, South Africa (the BRICS). It consists of three parts: Part I: the BRICS and the international tax regime; Part II: tax policy and technical tensions in the BRICS(+) world and Part III: the impact of the ascent of the BRICS.
Book Synopsis The Taxation of Business Profits Under Tax Treaties by : Brian J. Arnold
Download or read book The Taxation of Business Profits Under Tax Treaties written by Brian J. Arnold and published by . This book was released on 2003 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties by :
Download or read book The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties written by and published by . This book was released on 2012 with total page 1190 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions from five continents and empirically ascertains the impact of the UN and OECD Model Tax Conventions on bilateral tax treaties. It therefore fills a major gap in the international tax literature, which has so far either studied the sole Model Tax Conventions or focused on bilateral treaties in the context of the tax treaty policy of single countries, and sets the pace for a new methodology in the analysis and interpretation of tax treaties. A general report outlines the key points of the analysis, highlights current trends and predicts future developments of multilateralism and global tax law. This is an essential resource for academics, tax authorities and international tax practitioners who find textbooks based on Model Tax Conventions insufficient.
