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Courts And Tax Treaty Law
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Book Synopsis Courts and Tax Treaty Law by : Guglielmo Maisto
Download or read book Courts and Tax Treaty Law written by Guglielmo Maisto and published by IBFD. This book was released on 2007 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.
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.
Book Synopsis Judicial Interpretation of Tax Treaties by : Carlo Garbarino
Download or read book Judicial Interpretation of Tax Treaties written by Carlo Garbarino and published by Edward Elgar Publishing. This book was released on 2016-10-28 with total page 699 pages. Available in PDF, EPUB and Kindle. Book excerpt: Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.
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 Arbitration Under Tax Treaties by : Mario Züger
Download or read book Arbitration Under Tax Treaties written by Mario Züger and published by IBFD. This book was released on 2001 with total page 290 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of both the concluded and the proposed dispute resolution methods. The relationship between the current developments in tax treaty law and the more general trends of modern dispute resolution in public international law is investigated. Concludes with a summary and evaluation of several alternative methods of dispute resolution in recent treaty practice.
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 Interpretation of Tax Treaties under International Law by : F. A. Engelen
Download or read book Interpretation of Tax Treaties under International Law written by F. A. Engelen and published by IBFD. This book was released on 2004 with total page 615 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).
Book Synopsis Tax Treaty Interpretation by : Michael Lang
Download or read book Tax Treaty Interpretation written by Michael Lang and published by Kluwer Law International B.V.. This book was released on 2001-12-19 with total page 402 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed survey of tax treaty interpretations in 16 European countries taking into account court decisions since 1993, the OECD reports on partnership, changes in administrative practice at national level and recent Community law effecting taxation and tax practice.
Book Synopsis Settlement of Disputes in Tax Treaty Law by : Michael Lang
Download or read book Settlement of Disputes in Tax Treaty Law written by Michael Lang and published by Springer. This book was released on 2002-09 with total page 608 pages. Available in PDF, EPUB and Kindle. Book excerpt: A wide variety of legal approaches and techniques are presented in detail. Includes 18 country reports - from 14 EU Member States plus Norway, Hungary, Latvia, and the Czech Republic - as well as additional essays on such topics as international tax arbitration, social security conventions, the jurisdiction of international courts, and World Bank/ICSID dispute settlement procedures as all of these may be applied to the resolution of tax disputers.
Book Synopsis Tax Treaty Case Law around the Globe 2017 by : Michael Lang
Download or read book Tax Treaty Case Law around the Globe 2017 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2018-02-20 with total page 332 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided in 2016 around the world.
Book Synopsis Tax Treaty Case Law around the Globe 2021 by : Georg Kofler
Download or read book Tax Treaty Case Law around the Globe 2021 written by Georg Kofler and published by Linde Verlag GmbH. This book was released on 2022-07-19 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the thirty most important tax treaty cases that were decided around the world in 2020. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, "Tax Treaty Case Law around the Globe 2021" is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.
Book Synopsis Tax Treaty Case Law around the Globe 2020 by : Eric Kemmeren
Download or read book Tax Treaty Case Law around the Globe 2020 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2021-08-04 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that were decided around the world in 2019. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, “Tax Treaty Case Law around the Globe 2020” is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics
Book Synopsis Tax Treaty Case Law around the Globe 2022 by : Eric Kemmeren
Download or read book Tax Treaty Case Law around the Globe 2022 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2023-11-29 with total page 480 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that provides a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases that were decided around the world in 2021. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2022 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Book Synopsis Tax Treaty Case Law around the Globe 2016 by : Eric Kemmeren
Download or read book Tax Treaty Case Law around the Globe 2016 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2017-01-05 with total page 319 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases which were decided in 2015 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2016 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics.
Book Synopsis Tax Treaty Case Law around the Globe 2019 by : Michael Lang
Download or read book Tax Treaty Case Law around the Globe 2019 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2020-07-22 with total page 309 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Book Synopsis Tax Treaty Case Law around the Globe 2020 by : Eric Kemmeren
Download or read book Tax Treaty Case Law around the Globe 2020 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2021-08-04 with total page 402 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that were decided around the world in 2019. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, “Tax Treaty Case Law around the Globe 2020” is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Book Synopsis Tax Treaty Case Law around the Globe 2018 by : Eric Kemmeren
Download or read book Tax Treaty Case Law around the Globe 2018 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2019-06-13 with total page 394 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 35 most important tax treaty cases which were decided around the world in 2017. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2018 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
