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Thin Capitalisation Taxation Of Entertainers Artistes And Sportsmen
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Book Synopsis Issues in International Taxation Thin Capitalisation - Taxation of Entertainers, Artistes and Sportsmen by : OECD
Download or read book Issues in International Taxation Thin Capitalisation - Taxation of Entertainers, Artistes and Sportsmen written by OECD and published by OECD Publishing. This book was released on 1987-05-02 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication brings together two reports prepared by the Committee on Fiscal Affairs; "Thin Capitalisation" and "The Taxation of Income Derived from Entertainment, Artistic and Sporting Activities",
Author :Organisation for Economic Co-operation and Development Publisher :Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications and Information Centre ISBN 13 : Total Pages :76 pages Book Rating :4.:/5 (41 download)
Book Synopsis Thin Capitalisation ; Taxation of Entertainers, Artistes and Sportsmen by : Organisation for Economic Co-operation and Development
Download or read book Thin Capitalisation ; Taxation of Entertainers, Artistes and Sportsmen written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications and Information Centre. This book was released on 1987 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the first report the various forms that hidden capitalisation can take are examined, the implications for tax yields and the ways in which countries can use double taxation treaties to deal with these situations. In the second report the problems that arise for tax authorities from entertainment and sporting activities are described and the measures they have taken to counteract non-compliance in this area.
Book Synopsis Taxation of International Performing Artistes by : Dick Molenaar
Download or read book Taxation of International Performing Artistes written by Dick Molenaar and published by IBFD. This book was released on 2005 with total page 439 pages. Available in PDF, EPUB and Kindle. Book excerpt: The special tax rules for performing artistes lead to obstacles. This book considers the problems regarding, for example, the determination of taxable income and the non-deductibility of expenses and tax credits in the country of residence, and gives clear examples of excessive taxation.
Book Synopsis Taxation of Entertainers, Athletes, and Artists by : Lionel S. Sobel
Download or read book Taxation of Entertainers, Athletes, and Artists written by Lionel S. Sobel and published by American Bar Association. This book was released on 2015 with total page 390 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the specialized issues affecting the income taxation of entertainers, athletes, and artists. It considers both domestic and international taxation. It includes numerous examples, calculations, charts and graphs.
Book Synopsis The Taxation of International Entertainers and Athletes:All the World's a Stage by : Daniel Sandler
Download or read book The Taxation of International Entertainers and Athletes:All the World's a Stage written by Daniel Sandler and published by Springer. This book was released on 1995-09-21 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Taxation of International Entertainers and Athletes: All the World's a Stage provides a comprehensive and detailed analysis of the taxation of non-resident entertainers and athletes in seven countries: Australia, Canada, France, Germany, Japan, the United Kingdom and the United States. The book deals with the many sources of income which such individuals can derive, including income from live performances, television appearances, commercials, product endorsements, royalties for record sales or `needle time', and merchandising of concert paraphernalia. The primary focus of the book is income tax, although VAT regimes are also considered. In addition, the book provides in-depth analysis of Article 17 (Artists and Sportsmen) of the OECD Model Tax Treaty, particularly regarding the extensive additions to the Commentary to that Article made in 1992 based on the OECD's 1987 report on the taxation of entertainers and athletes. The book contains a table summarising the tax treaty provisions applicable to personal services income derived by entertainers and athletes in the seven countries reviewed. Two examples (one dealing with a touring pop group and the other with a professional tennis player) are used to illustrate, compare and contrast the manner in which income earned by non-resident entertainers and athletes is treated under domestic income tax and VAT regimes (where applicable) in these countries. Finally, conclusions are drawn, at the domestic and international levels, regarding policy and practical considerations in the effective and efficient taxation of such individuals.
Book Synopsis Tax and Financial Planning for Sportsmen and Entertainers by : Richard Baldwin
Download or read book Tax and Financial Planning for Sportsmen and Entertainers written by Richard Baldwin and published by Lexis Law Publishing (Va). This book was released on 1987 with total page 198 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Foreign Entertainers and Sportsmen by : Beate Erwin
Download or read book Taxation of Foreign Entertainers and Sportsmen written by Beate Erwin and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: " ... analyzes the U.S. income tax laws applicable to nonresident alien artists, performing artists, entertainers, and athletes (together referred to as "performers") who derive income from U.S. sources, either relating to performances in the United States or rights extending to intellectual property rights in the United States"--Portfolio description (page iii).
Book Synopsis The Impact of Community Law on Tax Treaties:Issues and Solutions by : Pasquale Pistone
Download or read book The Impact of Community Law on Tax Treaties:Issues and Solutions written by Pasquale Pistone and published by Kluwer Law International B.V.. This book was released on 2002-03-11 with total page 424 pages. Available in PDF, EPUB and Kindle. Book excerpt: Study on the question of harmonization of direct taxation among European Community Member States: how Member States must comply with EC Law as they apply their tax treaties, how EC law regulates cross-border tax issues within the Community, and how EC law affects tax treaties between EU Member States and third countries. The book provides expert commentary on 27 leading tax cases from the European Court of Justice, and gives the proposal of EC Model Tax Convention, which combines existing provisions of international tax law with the principles of Community tax law.
Book Synopsis Taxation of Artistes and Sportsmen in International Tax Law by : Walter Loukota
Download or read book Taxation of Artistes and Sportsmen in International Tax Law written by Walter Loukota and published by . This book was released on 2007 with total page 502 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Taxation of Entertainers and Sportspersons Performing Abroad by : Guglielmo Maisto
Download or read book Taxation of Entertainers and Sportspersons Performing Abroad written by Guglielmo Maisto and published by . This book was released on 2016 with total page 600 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxation of Entertainers and Sportspersons Performing Abroad', comprising the proceedings and working documents of an annual seminar held in Milan in November 2015, is a detailed and comprehensive study on the taxation of highly mobile individuals engaged in the artistic and sports sectors. It begins with a comparative analysis of the domestic tax regime of such individuals and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union. 0The book then moves to selected tax treaty issues. In particular, it analyses: (i) the history of article 17 of the OECD Model Tax Convention; (ii) recent developments concerning that article, particularly the 2014 amendments to the Commentary on Article 17 of the OECD Model Convention; (iii) tax treaty issues related to qualification, allocation and apportionment of income derived by entertainers and sportspersons; and (iv) the taxation of income from image rights, sponsorship and advertising.
Book Synopsis BRICS and International Tax Law by : Peter Antony Wilson
Download or read book BRICS and International Tax Law written by Peter Antony Wilson and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version September 1992 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version September 1992 written by OECD and published by OECD Publishing. This book was released on 1992-10-19 with total page 243 pages. Available in PDF, EPUB and Kindle. Book excerpt: Condensed version of the loose-leaf publication "Model tax convention on income and capital", containing the full text of the September 1992 Model Tax Convention, but omitting the historical notes and annexes, which include a detailed list of tax conventions between OECD member countries and the text of the Recommendation of 23 July 1992 from the OECD Council.
Book Synopsis Klaus Vogel on Double Taxation Conventions by : Ekkehart Reimert
Download or read book Klaus Vogel on Double Taxation Conventions written by Ekkehart Reimert and published by Kluwer Law International B.V.. This book was released on 2022-01-18 with total page 3112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University
Book Synopsis Model Tax Convention on Income and on Capital 2010 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2010 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2012-08-06 with total page 2134 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the eighth 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 on Income and on Capital as it read on 22 July 2010.
Book Synopsis Model Tax Convention on Income and on Capital 2014 (Full Version) by : OECD
Download or read book Model Tax Convention on Income and on Capital 2014 (Full Version) written by OECD and published by OECD Publishing. This book was released on 2015-10-30 with total page 2288 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the ninth 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 on Income and on Capital as it read on 15 July 2014.
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 2800 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 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.
