Read Books Online and Download eBooks, EPub, PDF, Mobi, Kindle, Text Full Free.
Departures From The Oecd Model And Commentaries
Download Departures From The Oecd Model And Commentaries full books in PDF, epub, and Kindle. Read online Departures From The Oecd Model And Commentaries ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!
Book Synopsis Departures from the OECD Model and Commentaries by : Guglielmo Maisto
Download or read book Departures from the OECD Model and Commentaries written by Guglielmo Maisto and published by . This book was released on 2014 with total page 598 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions including Australia, Austria, Belgium, China, Germany, Italy, the Netherlands, Spain and the United States. This book is essential reading for all those dealing with tax treaty issues and EU tax law."--Extracted from publisher website on May 19, 2015.
Book Synopsis The Commentaries on the OECD Model as a Mechanism for Interpretation with Reference to the Swedish Perspective by : K. Cejie
Download or read book The Commentaries on the OECD Model as a Mechanism for Interpretation with Reference to the Swedish Perspective written by K. Cejie and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article considers the question of the importance of the Commentaries on the OECD Model and, in particular, whether an ambulatory or a static approach to changes in the OECD Commentaries should be adopted. The point of departure is international tax law, with an emphasis on the Swedish perspective. Recent case law from the Supreme Administrative Court is also considered.
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.
Book Synopsis Text of the OECD Model Convention : Commentaries on the Articles of the OECD Model Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital : Amendments to the Commentaries on Articles 9, 10, 11 and 12 of the OECD Model Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital by :
Download or read book Text of the OECD Model Convention : Commentaries on the Articles of the OECD Model Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital : Amendments to the Commentaries on Articles 9, 10, 11 and 12 of the OECD Model Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital written by and published by . This book was released on 1977 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The 2003 Revision of the OECD Commentaries on the Improper Use of Tax Treaties by : Adolfo Martin Jimenez
Download or read book The 2003 Revision of the OECD Commentaries on the Improper Use of Tax Treaties written by Adolfo Martin Jimenez and published by . This book was released on 2014 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the OECD's new position regarding the improper use/abuse of double taxation treaties introduced in the January 2003 revision of the OECD Model Tax Convention and Commentaries. Although the most important changes were added in the Commentary on Art. 1 of the OECD Model, other articles or their Commentary have also been affected. This article first focuses on the new Commentary added to Art. 1 on the improper use of tax treaties and the Commentaries on the other articles closely related it. The article next studies the new commentaries and changes to the OECD Model which deal with topics relating to access to tax treaties and their improper use. The article then summarizes this author's opinion on the new Commentaries on the improper use/abuse of tax treaties and also connects the first sections of the article to another part which considers whether the Commentaries added in 2003 affect prior treaties. This includes some general thoughts on whether the effect of the OECD Commentaries on treaty interpretation is overestimated and whether the Commentaries should be downgraded in their effect on treaties because they affect taxpayers' rights. Some reflections on how to improve the declining effect of the OECD Commentaries close this work.
Book Synopsis The New Permanent Establishment by : Tiago Gonçalves Marques
Download or read book The New Permanent Establishment written by Tiago Gonçalves Marques and published by Leya. This book was released on 2023-04-21 with total page 397 pages. Available in PDF, EPUB and Kindle. Book excerpt: This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.
Book Synopsis Access to Treaty Benefits by : Desiree Auer
Download or read book Access to Treaty Benefits written by Desiree Auer and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.
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 OECD Arbitration in Tax Treaty Law by : Alicja Majdanska
Download or read book OECD Arbitration in Tax Treaty Law written by Alicja Majdanska and published by Linde Verlag GmbH. This book was released on 2018-09-14 with total page 740 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes.
Book Synopsis Other Income under Tax Treaties by : Alexander Bosman
Download or read book Other Income under Tax Treaties written by Alexander Bosman and published by Kluwer Law International B.V.. This book was released on 2015-09-23 with total page 610 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bilateral tax treaties are often, to a greater or lesser extent, based on the OECD Model Convention. Among the distributive rules with respect to taxation of income which are laid down in Chapter III of that model, Article 21 assigns the tax jurisdiction in respect of "other income" - understood to mean items of income which are not dealt with in other provisions of the tax treaty - to the residence state in accordance with the main rule underlying the OECD Model, thus ensuring that no income falls outside the scope of the treaty. This study provides a comprehensive analysis of Article 21 of the OECD Model. In extensive detail, and with reference to case law from a number of jurisdictions and to statements of various authorities and official documents, the author shows how Article 21 operates in relation to the other distributive rules of the OECD Model and bilateral tax treaties based thereon. The analysis considers such items of income as the following in relation to Article 21: - income from immovable property; - business profits; - profits from shipping, inland waterways transport, and air transport; - dividends, interest, and royalties; - capital gains; and - income from employment. In addition, the author examines the significance of the OECD Commentaries for the interpretation of tax treaties, the "other income" article in other model conventions, and notable deviations from Article 21 among bilateral tax treaties. An appendix offers well-grounded recommendations on how to potentially amend the wording of Article 21 and the related commentary and how the application of the article can be improved. Although underexposed in the tax law literature heretofore, the "other income" article raises important international taxation issues that remain problematic or unresolved. Tax lawyers, government officials, and other interested professionals will find here a penetrating analysis that goes a long way towards clarifying the characterisation of income that resists the standard categories defined in tax treaties.
Book Synopsis Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, with Respect to Fiscally Transparent Entities by : A. Nikolakakis
Download or read book Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, with Respect to Fiscally Transparent Entities written by A. Nikolakakis and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article sets out some reflections of the authors on those aspects of the OECD's October 2015 final report on Neutralising the Effects of Hybrid Mismatch Arrangements (the Hybrids Report) that relate to revisions to the OECD Model to add a specific provision on fiscally transparent entities (as a new Article 1(2)), and to build on the Commentaries already in place in this regard (the HR Proposals). It also considers the similar and related provisions contained in the multilateral instrument to implement the tax treaty related BEPs measures (the MLI) that was released on 24 November 2016. The authors conduct an extensive review of the issues and raise a number of interpretive and technical questions, as well as policy considerations. This review is set against the backdrop of an examination of similar provisions (or provisions with similar purposes) in the US Models and in various existing bilateral treaties, as well as under domestic laws, of the countries represented by the authors. The authors also provide some observations with respect to potential scope and drafting or implementation of alternatives, with a view to contributing to the ongoing international debate and reform project.
Book Synopsis The Concept of Permanent Establishment in the Insurance Business by : Daniele Frescurato
Download or read book The Concept of Permanent Establishment in the Insurance Business written by Daniele Frescurato and published by Kluwer Law International B.V.. This book was released on 2021-04-22 with total page 430 pages. Available in PDF, EPUB and Kindle. Book excerpt: siness models adopted by insurance companies; and comparative analysis of double tax treaty policies adopted in a number of countries with respect to the permanent establishment provision in the insurance business, highlighting Switzerland for comparative purposes. In a concluding chapter, the author proposes changes to the definition of the dependent agent permanent establishment currently enshrined in the model treaties and their respective commentaries, aligning such a definition to the regulatory framework in which insurance companies conduct their business in countries other than that of incorporation. As a highly significant and timely contribution to the study of the interplay between insurance regulation and tax implications, this very original work will prove of especial value to practitioners in international tax and insurance law, as well as professionals in the financial services sector and tax academics.
Book Synopsis The Retroactive Effect of Changes to the Commentaries on the OECD Model by : Dirk Broekhuijsen
Download or read book The Retroactive Effect of Changes to the Commentaries on the OECD Model written by Dirk Broekhuijsen and published by . This book was released on 2016 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article discusses the temporal aspects of tax treaties. In particular, it focuses on whether the legitimate expectations of taxpayers are harmed when changes are made to the Commentaries on the OECD Model. How are taxpayers' rights considered when they have already entered into a certain factual or legal position?
Book Synopsis A Global Analysis of Tax Treaty Disputes by : Eduardo Baistrocchi
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
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 417 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 2016. 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, the proposed book is a valuable reference tool for all tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics who are active in tax treaty case law.
Book Synopsis Internal Revenue Cumulative Bulletin by : United States. Internal Revenue Service
Download or read book Internal Revenue Cumulative Bulletin written by United States. Internal Revenue Service and published by . This book was released on 1994 with total page 936 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, with Respect to Fiscally Transparent Entities - Part 2 by : A. Nikolakakis
Download or read book Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, with Respect to Fiscally Transparent Entities - Part 2 written by A. Nikolakakis and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Part 2 of this article concludes the authors' examination of the OECD's proposals regarding fiscally transparent entities and the provisions of the Multilateral Instrument based on experience in considering and working with similar measures in existing treaties, including a consideration of the relevant interpretive and technical questions, and policy issues.
