International Cooperation in Tax Matters

Download International Cooperation in Tax Matters PDF Online Free

Author :
Publisher :
ISBN 13 :
Total Pages : 132 pages
Book Rating : 4.3/5 (91 download)

DOWNLOAD NOW!


Book Synopsis International Cooperation in Tax Matters by : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters

Download or read book International Cooperation in Tax Matters written by United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters and published by . This book was released on 1998 with total page 132 pages. Available in PDF, EPUB and Kindle. Book excerpt: Report of the Ad Hoc Group of Experts on International Cooperation in Tax Matters on the work of its eighth meeting which was held from 15 to 19 December 1997 in Geneva, including selected papers presented at the meeting.

International Cooperation in Tax Matters

Download International Cooperation in Tax Matters PDF Online Free

Author :
Publisher : New York : United Nations
ISBN 13 :
Total Pages : 48 pages
Book Rating : 4.3/5 (91 download)

DOWNLOAD NOW!


Book Synopsis International Cooperation in Tax Matters by : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters

Download or read book International Cooperation in Tax Matters written by United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters and published by New York : United Nations. This book was released on 1992 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: The master-storyteller turns his pen to rural village life with Ways of Sunlight in Trinidad: gossip and rivalry between village washerwomen; toiling cane-cutters reaping their harvest; superstitious old Ma Procop protecting the fruit of her Mango tree with magic. With equal wit and sensitivity, he reflects the depression of hard times in London, where people live in cold, damp basements, hustling for survival.

International Cooperation in Tax Matters

Download International Cooperation in Tax Matters PDF Online Free

Author :
Publisher :
ISBN 13 :
Total Pages : 238 pages
Book Rating : 4.3/5 (91 download)

DOWNLOAD NOW!


Book Synopsis International Cooperation in Tax Matters by : United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters

Download or read book International Cooperation in Tax Matters written by United Nations. Ad Hoc Group of Experts on International Co-operation in Tax Matters and published by . This book was released on 1997 with total page 238 pages. Available in PDF, EPUB and Kindle. Book excerpt: Selected papers on transfer pricing, globalization of capital markets, taxation of derivatives and new financial instruments, taxation of students and teachers, and technical assistance in international taxation. Also included is a comparison of the UN and OECD Model Conventions with over 50 tax treaties between developed and developing countries.

The Interface of International Trade Law and Taxation

Download The Interface of International Trade Law and Taxation PDF Online Free

Author :
Publisher : IBFD
ISBN 13 : 9087221827
Total Pages : 339 pages
Book Rating : 4.0/5 (872 download)

DOWNLOAD NOW!


Book Synopsis The Interface of International Trade Law and Taxation by : Jennifer E. Farrell

Download or read book The Interface of International Trade Law and Taxation written by Jennifer E. Farrell and published by IBFD. This book was released on 2013 with total page 339 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book explores the ill-defined and oft-underestimated relationship between the World Trade Organization (WTO) and taxation. By adopting a two-pronged approach, the relationship is examined in terms of the extent to which the WTO legal framework exerts influence upon domestic tax law and international tax policy, and whether it is appropriate for the WTO to play a regulatory role in the field of taxation. The book begins with an examination of the historical development of international trade law and international tax law, and demonstrates that these two separate areas of law are closely linked in terms of their underlying principles and historical evolution. The work then goes on to offer a doctrinal analysis of the tax content found in the WTO legal texts and highlights ambiguities therein.

IBFD International Tax Glossary

Download IBFD International Tax Glossary PDF Online Free

Author :
Publisher : IBFD
ISBN 13 : 908722057X
Total Pages : 561 pages
Book Rating : 4.0/5 (872 download)

DOWNLOAD NOW!


Book Synopsis IBFD International Tax Glossary by : Julie Rogers-Glabush

Download or read book IBFD International Tax Glossary written by Julie Rogers-Glabush and published by IBFD. This book was released on 2009 with total page 561 pages. Available in PDF, EPUB and Kindle. Book excerpt: Authoritative resource for defining tax and tax-related terms. With the addition of over 120 completely new definitions and over 100 substantially revised descriptions, this edition contains more than 2,000 tax terms, clearly and concisely defined in English; alphabetical listing of some 400 English terms together with their French, German, Spanish and Dutch equivalents; cross-referenced listing of terms indicating similar, related and contrasting terms; abbreviations and bibliographical references to aid further research; a list of tax-related organizations, with brief descriptions and Internet addresses; accurate descriptions of both traditional and more obscure terms; expanded coverage of terms relating to customs, VAT, capital taxes, transfer pricing and EU tax law terminology; a separate extensive list of tax-related organizations in some 40 countries.

The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention

Download The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention PDF Online Free

Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403543078
Total Pages : 330 pages
Book Rating : 4.4/5 (35 download)

DOWNLOAD NOW!


Book Synopsis The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention by : David Orzechowski-Zölzer

Download or read book The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention written by David Orzechowski-Zölzer and published by Kluwer Law International B.V.. This book was released on 2024-05-21 with total page 330 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and other allocation rules of the UN Model. The book’s analysis focuses on the interpretation of the concept of technical services by examining the historical evolution of Article 12 of the OECD and UN Models and the systematic context in which it is embedded. Aspects of this analysis examined include the following: the base-erosion principle as justification for establishing source taxing rights without the physical presence of the service provider in the state in which fees for technical services arise; whether the term ‘technical’ is sufficiently defined in the Commentaries to the UN Model or whether it shall be ascribed a different meaning to increase legal certainty for tax authorities and taxpayers; relevance of the OECD Model and its Commentaries as the basis for the UN Model and its Commentaries; rules of precedence concerning the application of Article 12A in relation to the other allocation rules of the UN Model; the connection between royalties and fees for technical services; application of Article 12A UN Model to challenges arising from the digitalized economy; and the allocation of taxing rights for fees for technical services rendered in a third state. Tax treaties of selected African countries are examined, as these countries were the earliest adopters of the concept of fees for technical services into their tax treaty network. The book also provides an overview of literature and jurisprudence on country practices in Brazil, India, and other countries, as well as relevant documents of international organizations. This book provides practitioners, government officials, and academics with a deep understanding of the interpretation and application of Article 12A UN Model. It will prove of great value in preparing for tax treaty negotiations and also in informing and advising enterprises that intend to conduct business in developing countries through the provision of specialized services.

A Global Agenda

Download A Global Agenda PDF Online Free

Author :
Publisher : University Press of America
ISBN 13 : 9780934654906
Total Pages : 364 pages
Book Rating : 4.6/5 (549 download)

DOWNLOAD NOW!


Book Synopsis A Global Agenda by : John Tessitore

Download or read book A Global Agenda written by John Tessitore and published by University Press of America. This book was released on 1991 with total page 364 pages. Available in PDF, EPUB and Kindle. Book excerpt: To find more information about Rowman and Littlefield titles, please visit www.rowmanlittlefield.com.

International Regulatory Co-operation: Case Studies, Vol. 1 Chemicals, Consumer Products, Tax and Competition

Download International Regulatory Co-operation: Case Studies, Vol. 1 Chemicals, Consumer Products, Tax and Competition PDF Online Free

Author :
Publisher : OECD Publishing
ISBN 13 : 9264200487
Total Pages : 90 pages
Book Rating : 4.2/5 (642 download)

DOWNLOAD NOW!


Book Synopsis International Regulatory Co-operation: Case Studies, Vol. 1 Chemicals, Consumer Products, Tax and Competition by : OECD

Download or read book International Regulatory Co-operation: Case Studies, Vol. 1 Chemicals, Consumer Products, Tax and Competition written by OECD and published by OECD Publishing. This book was released on 2013-04-30 with total page 90 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume complements the stocktaking report on International Regulatory Co-operation: Rules for a Global World by providing evidence on regulatory co-operation in four sectors: chemical safety, consumer product safety, model tax convention, and competition law enforcement.

Oppenheim's International Law: United Nations

Download Oppenheim's International Law: United Nations PDF Online Free

Author :
Publisher : Oxford University Press
ISBN 13 : 0192537180
Total Pages : 1642 pages
Book Rating : 4.1/5 (925 download)

DOWNLOAD NOW!


Book Synopsis Oppenheim's International Law: United Nations by : Rosalyn Higgins

Download or read book Oppenheim's International Law: United Nations written by Rosalyn Higgins and published by Oxford University Press. This book was released on 2018-12-13 with total page 1642 pages. Available in PDF, EPUB and Kindle. Book excerpt: The United Nations, whose specialized agencies were the subject of an Appendix to the 1958 edition of Oppenheim's International Law: Peace, has expanded beyond all recognition since its founding in 1945.This volume represents a study that is entirely new, but prepared in the way that has become so familiar over succeeding editions of Oppenheim. An authoritative and comprehensive study of the United Nations' legal practice, this volume covers the formal structures of the UN as it has expanded over the years, and all that this complex organization does. All substantive issues are addressed in separate sections, including among others, the responsibilities of the UN, financing, immunities, human rights, preventing armed conflicts and peacekeeping, and judicial matters. In examining the evolving structures and ever expanding work of the United Nations, this volume follows the long-held tradition of Oppenheim by presenting facts uncoloured by personal opinion, in a succinct text that also offers in the footnotes a wealth of information and ideas to be explored. It is book that, while making all necessary reference to the Charter, the Statute of the International Court of Justice, and other legal instruments, tells of the realities of the legal issues as they arise in the day to day practice of the United Nations. Missions to the UN, Ministries of Foreign Affairs, practitioners of international law, academics, and students will all find this book to be vital in their understanding of the workings of the legal practice of the UN. Research for this publication was made possible by The Balzan Prize, which was awarded to Rosalyn Higgins in 2007 by the International Balzan Foundation.

Joint Committee Print, Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal Part One:, ... September 2009

Download Joint Committee Print, Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal Part One:, ... September 2009 PDF Online Free

Author :
Publisher :
ISBN 13 :
Total Pages : 260 pages
Book Rating : 4.3/5 ( download)

DOWNLOAD NOW!


Book Synopsis Joint Committee Print, Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal Part One:, ... September 2009 by :

Download or read book Joint Committee Print, Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal Part One:, ... September 2009 written by and published by . This book was released on 2009 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Yearbook of the United Nations, Volume 46 (1992)

Download Yearbook of the United Nations, Volume 46 (1992) PDF Online Free

Author :
Publisher : Martinus Nijhoff Publishers
ISBN 13 : 9004636781
Total Pages : 1294 pages
Book Rating : 4.0/5 (46 download)

DOWNLOAD NOW!


Book Synopsis Yearbook of the United Nations, Volume 46 (1992) by : United Nations

Download or read book Yearbook of the United Nations, Volume 46 (1992) written by United Nations and published by Martinus Nijhoff Publishers. This book was released on 2023-08-28 with total page 1294 pages. Available in PDF, EPUB and Kindle. Book excerpt: Fully indexed, the 1992 edition of the Yearbook is the single most current, comprehensive and authoritative reference publication about the work of the United Nations, other international organizations and related bodies. The book is designed not just for use by diplomats, officials and scholars but also by other researchers, writers, journalists, teachers and students. The year 1992 was a remarkably eventful one for the United Nations and in the conduct of international relations. This volume of the Yearbook details the activities of the United Nations, its many organs, agencies and programmes, working together to rekindle a new form of multilateral cooperation for a better world. It records the diverse and globe-encompassing activities of the United Nations and its enduring efforts to deal with the world's pressing concerns, particularly matters of international peace and security, disarmament, human rights, the settlement of regional conflicts, economic and social development, the preservation of the environment, control of drugs and narcotic substance abuse, crime prevention, adequate shelter, youth and the ageing and humanitarian assistance for refugees as well as disaster relief. The Yearbooks for the years 1988, 1989 and 1990 are expected to be published within the next two years.

United Nations Documents Index

Download United Nations Documents Index PDF Online Free

Author :
Publisher : UN
ISBN 13 : 9789211011456
Total Pages : 1250 pages
Book Rating : 4.0/5 (114 download)

DOWNLOAD NOW!


Book Synopsis United Nations Documents Index by : United Nations

Download or read book United Nations Documents Index written by United Nations and published by UN. This book was released on 2007-01-06 with total page 1250 pages. Available in PDF, EPUB and Kindle. Book excerpt: The United Nations Documents Index provides information on documents and publications issued by United Nations offices worldwide. The information is presented in nine sections covering the areas of documents and publications; official records; sales publications; United Nations maps included in UN documents; United Nations sheet maps; United Nations document series symbols; author index; title index and subject index. The index is a three part set. Publishing Agency: United Nations (UN).

Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal: Provisions related to the taxation of cross-border income and investment

Download Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal: Provisions related to the taxation of cross-border income and investment PDF Online Free

Author :
Publisher :
ISBN 13 :
Total Pages : 262 pages
Book Rating : 4.:/5 (327 download)

DOWNLOAD NOW!


Book Synopsis Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal: Provisions related to the taxation of cross-border income and investment by : United States. Congress. Joint Committee on Taxation

Download or read book Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal: Provisions related to the taxation of cross-border income and investment written by United States. Congress. Joint Committee on Taxation and published by . This book was released on 2009 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal, Part Three: Provisions Related to the Taxation of Cross-Border Income and Investment, September 2009, [Joint Committee Print]

Download Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal, Part Three: Provisions Related to the Taxation of Cross-Border Income and Investment, September 2009, [Joint Committee Print] PDF Online Free

Author :
Publisher :
ISBN 13 :
Total Pages : 258 pages
Book Rating : 4.3/5 (91 download)

DOWNLOAD NOW!


Book Synopsis Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal, Part Three: Provisions Related to the Taxation of Cross-Border Income and Investment, September 2009, [Joint Committee Print] by :

Download or read book Description of Revenue Provisions Contained in the President's Fiscal Year 2010 Budget Proposal, Part Three: Provisions Related to the Taxation of Cross-Border Income and Investment, September 2009, [Joint Committee Print] written by and published by . This book was released on 2009 with total page 258 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Description of Revenue Provisions Contained in the President's Fiscal Year ... Budget Proposal

Download Description of Revenue Provisions Contained in the President's Fiscal Year ... Budget Proposal PDF Online Free

Author :
Publisher :
ISBN 13 :
Total Pages : 260 pages
Book Rating : 4.F/5 ( download)

DOWNLOAD NOW!


Book Synopsis Description of Revenue Provisions Contained in the President's Fiscal Year ... Budget Proposal by :

Download or read book Description of Revenue Provisions Contained in the President's Fiscal Year ... Budget Proposal written by and published by . This book was released on 2009 with total page 260 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Annual Review of United Nations Affairs 2008/2009

Download Annual Review of United Nations Affairs 2008/2009 PDF Online Free

Author :
Publisher :
ISBN 13 : 0195398009
Total Pages : 447 pages
Book Rating : 4.1/5 (953 download)

DOWNLOAD NOW!


Book Synopsis Annual Review of United Nations Affairs 2008/2009 by : Joachim Müller

Download or read book Annual Review of United Nations Affairs 2008/2009 written by Joachim Müller and published by . This book was released on 2010-04-15 with total page 447 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since the publication of its first edition in 1950, the Annual Review of United Nations Affairs has stood as the authoritative resource for scholars, students, and practitioners researching the latest developments of that august body. From the insightful introduction, prepared each year by a distinguished expert on UN affairs, to the full-text presentation of reports and resolutions and the helpful subject index, ARUNA provides a practical tour of each year's U.N. actions and debates. Theexpert selection of documents by Joachim Muller and Karl Sauvant and the topic-based organization of those documents make any researcher's task much easier than the vast searching, sorting, and pruning required by the U.N.'s website. The series' topic-based organization of the materials and subject index lend invaluable guidance to all researchers. ARUNA presents a comprehensive documentation of the work of the UN on an annual basis, starting in September of each year with the beginning of the regular sessions of the General Assembly. Coverage of the UN's key organs is provided, including the General Assembly, the Security Council, the Economic and Social Council (ECOSOC), the International Court of Justice, and the UN Secretariat. In addition, selected reports of intergovernmental bodies and expert groups are included. Solely official UN documentation is used. ARUNA occupies a special place in the publications on the work of the UN - it allows readers to obtain an overview ofthe principal developments in its key organs. This makes it an important reference source for policy-makers and academic researchers. The highlight of this year's edition is the introductory essay written by the highly esteemed Jose Antonio Ocampo, who is Professor of Professional Practice in International and Public Affairs, Director of the Program in Economic and Political Development at the School of International and Public Affairs, and Fellow of the Committee on Global Thought, ColumbiaUniversity. Professor Ocampo previously held the positions of Under-Secretary-General of the United Nations for Economic and Social Affairs, Executive Secretary of the United Nations Economic Commission for Latin America and the Caribbean, and Minister of Finance of Colombia. In 2009, he was a member of the Commission of Experts of the President of the United Nations General Assembly on Reforms of the International Monetary and Financial System. Professor Ocampo is also the author of numerousbooks and articles on macroeconomics policy and theory, economic development, international trade, and economic history. His recent publications include Stability with Growth: Macroeconomics, Liberalization and Development, with Joseph E. Stiglitz, Shari Spiegel, Ricardo Ffrench-Davis and Deepak Nayyar (New York: Oxford University Press, 2006). Professor Ocampo, relying on his expertise as a policy economist and his own considerable experience working on economic issues at the United Nations, has written an incisive introductory essay focusing on the United Nations and the global economic crisis. Professor Ocampo's essay examines the history of the economic policy recommendations of UN institutions and concludes that they have often been more far-sighted and accurate than those of the Bretton Woods Institutions, including the World Bank and the International Monetary Fund. He applies this analysis in particular to the recent global financial crisis, and shows how the Monterrey Consensus of 2002, which once again made the UN a forum for global economic issues, gave serious consideration to the concerns of developing countries and set many goals that might have helped to stave off the global financial crisis if they had been more actively pursued. Professor Ocampo also examines the UN's role in the wake of the global financial meltdown, particularly with regard to the Doha follow-up Conference and the Commission of Experts on Reforms of the International Monetary and Financial System, convened by the General Assembly and led by Joseph Stiglitz. In spite of some resistance to these initiatives from the United States and other developed countries, Professor Ocampo advocates in this essay for a more influential role for the UN's institutions in global financial reform, especially in light of their superior track record in anticipating economic problems resulting from "the inherent tendency of financial markets to experience boom-bust cycles." The 2008-2009 volumes of ARUNA therefore also devote considerable attention to the financial crisis as well as other international crises. Among the documents in the 2008-2009 volumes are the complete General Assembly resolutions, as well as the Report and Resolutions of the Security Council and the Economic and Social Council (ECOSOC). Annual Reports of note include reports of the United Nations Children's Fund (UNICEF), the UN Development Programme and UN Population Fund, the UN High Commissioner for HumanRights, the UN High Commissioner for Refugees, the UN Relief and Works Agency for Palestine Refugee in the Near East, and the World Food Programme. Mr. Muller and Dr. Sauvant have also selected progress reports on key peacekeeping, peace-building, and political missions, including those for Afghanistan, the Democratic Republic of the Congo, Haiti, Iraq, Kosovo, the Middle East, Somalia, Sudan, and West Africa. Each annual edition of ARUNA is introduced by a Guest Author, a distinguished expert on UN affairs, who highlights the outstanding themes of the year in review. Together with an overview provided by the editors, this introduction is intended to facilitate access to the material and, above all, to make it easer for users of ARUNA to "see the forest for the trees". As has been mentioned above, ARUNA is fortunate this year to have Jose Antonio Ocampo as the author of its introduction, but the roster of distinguished experts who have contributed this introduction in the past is also worthy of mention: Jeffrey D. Sachs: ARUNA 2007/2008 edition Professor Jeffrey D. Sachs is Director of the Earth Institute at Columbia University and Special Advisor to the Secretary-General of the UN on the Millennium Development Goals. Professor Sachs's introduction to ARUNA 2007/2008 was titled "Towards a New Global Protocol on Climate Change", in which he argued that solving the climate change problem will demand four steps: scientific consensus, public awareness, the development of alternative technologies, and a global framework for action. He dealt, in particular, with the science underpinning the negotiations for a new global protocol on climate change, as a successor to the Kyoto Protocol. Professor Sachs argued that climate change crises can only be solved through the goals, leadership, and treaty mechanisms of the UN. Edward C. Luck: ARUNA 2006/2007 edition Professor Edward C. Luck is UN Special Advisor on the Responsibility to Protect and Vice President and Director of Studies at the International Peace Academy. From 1984 to 1994, he served as President and Chief Executive Officer of the UN Association of the USA (UNA-USA). Professor Luck's introduction to ARUNA 2006/2007 covered "The responsible sovereign and the responsibility to protect", in which he addressed the scope and content of what was agreed at the 2005 World Summit, the implications of the responsibility to protect (RtoP) for notions of state sovereignty, and some of the conceptual, architectural, and policy challenges then facing UN Secretary-General Ban Ki-moon's commitment to "operationalizing" the responsibility to protect and translating it "from words to deeds". Louise Frechette: ARUNA 2005/2006 edition Ms Louise Frechette is Distinguished Fellow at the Centre for International Governance Innovation, Waterloo, Ontario. Until March 2006, she was the first Deputy Secretary-General of the UN; before that, she was Permanent Representative of Canada to the UN. Ms Frechette's introduction to ARUNA 2005/2006 covered "United Nations reform: an unfinished story". As the first Deputy Secretary-General of the UN, Ms Frechette was uniquely positioned to undertake a personal assessment of what has changed and what has not changed in the past decade at the UN and why. She examined if the UN is functioning better than it was 15 years ago, why reform is so difficult to achieve and what the future holds for the institutions. Rubens Ricupero: ARUNA 2004/2005 edition Mr Rubens Ricupero is Dean of the Fundacno Armando Alvares Penteado (FAAP), Sao Paulo and was formerly Secretary-General of UN Conference on Trade and Development (UNCTAD) and Minister of Finance of Brazil. Mr Ricupero's introduction to ARUNA 2004/2005 covered "The difficulty of building consensus in an age of extremes" and examined the mysteries of the negotiating process leading to the outcome of the 2005 World Summit. Rather than a "Grand Bargain" of a comprehensive UN reformin the areas of development, security and human rights, it is argued that the Summit ended more on a note of lamentation and regret over a missed opportunity. Mr Ricupero concludes that contrary to the daring proclamation at the outset by the Secretary-General, the conditions indispensable to succeed were not in place. Indeed, it was hard to imagine that an ambitious and balanced reform package for the UN could have had any real chance of succeeding.

Special Features of the UN Model Convention

Download Special Features of the UN Model Convention PDF Online Free

Author :
Publisher : Linde Verlag GmbH
ISBN 13 : 3709410401
Total Pages : 537 pages
Book Rating : 4.7/5 (94 download)

DOWNLOAD NOW!


Book Synopsis Special Features of the UN Model Convention by : Anna Binder

Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 537 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.