Nondiscrimination In International Tax Law

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The principle of non-discrimination in international and European tax law

Author : Niels Bammens
Publisher : IBFD
ISBN 13 : 9087221592
Total Pages : 1151 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis The principle of non-discrimination in international and European tax law by : Niels Bammens

Download or read book The principle of non-discrimination in international and European tax law written by Niels Bammens and published by IBFD. This book was released on 2012 with total page 1151 pages. Available in PDF, EPUB and Kindle. Book excerpt: The principle of non-discrimination plays a vital role in international and European tax law. This dissertation analyses the interpretation given to that principle in tax treaty practice and in the direct tax case law of the Court of Justice of the European Union (ECJ) on the fundamental freedoms. The objective of this analysis is twofold: to give a clear and thorough overview of both standards and to determine whether they share a common, underlying principle of non-discrimination. In order to achieve these objectives, a comprehensive selection of case law is discussed from the perspective of the two constitutive elements of discrimination, comparability and the existence of different treatment. Moreover, attention is drawn to the question whether a domestic measure that is found to be discriminatory may nevertheless be justified on the basis of reasons of public interest. Finally, the possible interplay between both standards is addressed.

Nondiscrimination in International Tax Law

Author : Kees van Raad
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.:/5 (919 download)

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Book Synopsis Nondiscrimination in International Tax Law by : Kees van Raad

Download or read book Nondiscrimination in International Tax Law written by Kees van Raad and published by . This book was released on 1986 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Nondiscrimination in International Tax Law

Author : Kees van Raad
Publisher : Springer
ISBN 13 : 9789065442666
Total Pages : 0 pages
Book Rating : 4.4/5 (426 download)

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Book Synopsis Nondiscrimination in International Tax Law by : Kees van Raad

Download or read book Nondiscrimination in International Tax Law written by Kees van Raad and published by Springer. This book was released on 1986-06-10 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Nondiscrimination in International Tax Law provides a discussion of the various restrictions which States must observe in taxing foreign persons. The author analyzes in-depth the restrictions imposed by the nondiscrimination clauses of Article 24 of the 1963 and 1977 OECD Model Double Taxation Conventions. In addition, attention is given to the deviations from these model clauses in the tax treaties concluded by the Netherlands and by the United States. The book includes a discussion of the tax-orientated national treatment and most favored nation clauses in Dutch and US commercial treaties. As the existing treaty nondiscrimination clauses suffer from a lack of consistency and underlying philosophy, in the final chapter an attempt is made to develop a comprehensive approach to equality in tax treatment of foreign persons. This title is published as number 6 in the Series on International Taxation

Non-discrimination in Tax Treaty Law and World Trade Law

Author : Kasper Dziurdź
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403509120
Total Pages : 715 pages
Book Rating : 4.4/5 (35 download)

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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.

Nondiscrimination in International Tax Law

Author :
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (14 download)

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Book Synopsis Nondiscrimination in International Tax Law by :

Download or read book Nondiscrimination in International Tax Law written by and published by . This book was released on 1986 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Non-Discrimination in Tax Treaties

Author : Pasquale Pistone
Publisher :
ISBN 13 : 9789087223793
Total Pages : 302 pages
Book Rating : 4.2/5 (237 download)

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Book Synopsis Non-Discrimination in Tax Treaties by : Pasquale Pistone

Download or read book Non-Discrimination in Tax Treaties written by Pasquale Pistone and published by . This book was released on 2016 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recoge: 1: Nationality Non-Discrimination and Article 24 OECD Model: Perennial Issues, Recent Trends and New Approaches - 2: Non-Discrimination on the Basis of Nationality in IIAs: A Latin American Tax Perspective - 3: Interest Deduction Limitations: When To Apply Articles 9 and 24(4) of the OECD Model? - 4: Revisiting the Application of the Capital Ownership Non-Discrimination Provision in Tax Treaties - 5: Non-Discrimination in Tax Treaties – Art. 24(4) and (5) OECD MC: A Russian Approach to Tax Treaty Interpretation - 6: Non-Discrimination and Harmful Tax Competition under WTO Law and Article 24 of the OECD Model - 7: Non-Discrimination: Can the EU Learn from the OECD Model Convention and Vice Versa? - 8: Non-Discrimination à la Cour: The ECJ’s (Lack of) Comparability Analysis in Direct Tax Cases - 9: Discriminatory Taxation and the European Convention on Human Rights.

The Principle of Non-discrimination in International and European Tax Law

Author : Niels Bammens
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (91 download)

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Book Synopsis The Principle of Non-discrimination in International and European Tax Law by : Niels Bammens

Download or read book The Principle of Non-discrimination in International and European Tax Law written by Niels Bammens and published by . This book was released on 2011 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Non-discrimination in European and Tax Treaty Law

Author : Kasper Dziurdź
Publisher :
ISBN 13 : 9783709407301
Total Pages : 0 pages
Book Rating : 4.4/5 (73 download)

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Book Synopsis Non-discrimination in European and Tax Treaty Law by : Kasper Dziurdź

Download or read book Non-discrimination in European and Tax Treaty Law written by Kasper Dziurdź and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Advanced Introduction to International Tax Law

Author : Reuven S. Avi-Yonah
Publisher : Edward Elgar Publishing
ISBN 13 : 1788978498
Total Pages : 231 pages
Book Rating : 4.7/5 (889 download)

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Book Synopsis Advanced Introduction to International Tax Law by : Reuven S. Avi-Yonah

Download or read book Advanced Introduction to International Tax Law written by Reuven S. Avi-Yonah and published by Edward Elgar Publishing. This book was released on 2019 with total page 231 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.

Non-discrimination rules in international taxation

Author : Willem F. G. Wijnen
Publisher :
ISBN 13 :
Total Pages : 40 pages
Book Rating : 4.:/5 (66 download)

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Book Synopsis Non-discrimination rules in international taxation by : Willem F. G. Wijnen

Download or read book Non-discrimination rules in international taxation written by Willem F. G. Wijnen and published by . This book was released on 1992 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Justice, Equality and Tax Law

Author : Nevia Čičin-Šain
Publisher : Linde Verlag GmbH
ISBN 13 : 3709412587
Total Pages : 541 pages
Book Rating : 4.7/5 (94 download)

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Book Synopsis Justice, Equality and Tax Law by : Nevia Čičin-Šain

Download or read book Justice, Equality and Tax Law written by Nevia Čičin-Šain and published by Linde Verlag GmbH. This book was released on 2022-10-05 with total page 541 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of the specific aspects of justice, equality and tax law "Justice, Equality and Tax Law" is a topic that is both old and new at the same time. Even if the society changes, the demands that tax needs to be just and equal seem to be immutable. What changes, of course, is the perception of the content of those demands. International taxation post-BEPS has been fraught with new challenges that warranted urgent responses. These challenges were mainly provoked by the unprecedented rise of the digital economy which truly marked a change in the way business is conducted, how value is created, and how goods and services are produced and consumed. Digitalization, in turn, had repercussions on all aspects of taxation - direct taxation, indirect taxation, and even tax procedures. For instance, the quest for more justice and equality in profit taxes was the reason why, in October 2021, a historical deal based on a two-pillar solution to address the tax challenges arising from the digitalization of the economy was negotiated within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting and agreed upon by 137 member countries. It was also the motive behind the shift from a typical vendor collection model to an intermediary collection model supported by centralized registration points in indirect taxes, notably the VAT/GST. Abundant data from the European Union or the OECD signalized an ever-increasing gap between expected VAT revenues and VAT actually collected, making it obvious that the classical system of VAT/GST collection was unable to respond to challenges posed by the digital economy. Therefore, new solutions based on the participation of digital platforms as intermediaries had been introduced. Finally, new technologies, such as blockchain, paved new avenues in enhancing tax compliance. In this context, this volume entitled "Justice, Equality, and Tax Law" contains not only a selection of the best master ́s theses of the full-time LL.M. programme in 2021/2022 but also represents an in-depth analysis of various aspects of this evergreen topic.

Non-discrimination Rules in International Taxation; Interpretation of Double Taxation Conventions

Author :
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (95 download)

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Book Synopsis Non-discrimination Rules in International Taxation; Interpretation of Double Taxation Conventions by :

Download or read book Non-discrimination Rules in International Taxation; Interpretation of Double Taxation Conventions written by and published by . This book was released on 1993 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Advanced Introduction to International Tax Law

Author : Reuven S. Avi-Yonah
Publisher : Edward Elgar Pub
ISBN 13 : 9781781952375
Total Pages : 123 pages
Book Rating : 4.9/5 (523 download)

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Book Synopsis Advanced Introduction to International Tax Law by : Reuven S. Avi-Yonah

Download or read book Advanced Introduction to International Tax Law written by Reuven S. Avi-Yonah and published by Edward Elgar Pub. This book was released on 2015-02-27 with total page 123 pages. Available in PDF, EPUB and Kindle. Book excerpt: 'Avi-Yonah's Advanced Introduction to International Taxation Law is a compact and accessible guide to the field. In effect, he has given us two books in one. The first is a very useful general guide to the basics of the rules and how they work in practice, with illuminating international comparisons to the often distinctive U.S. rules. The second is a clear and spirited defense of Avi-Yonah's particular views about international tax policy. These do not attract consensus in the field - nor do anyone else's views - but they can help stimulate further thinking about these complicated and important issues.'- Daniel Shaviro, New York University, USAdvanced Introduction to International Tax Law provides a concise yet wide-ranging overview of the key issues surrounding taxation and international law from a world authority on international tax.Systems of taxation deviate between jurisdictions and contrasting, income based levies on both individuals and enterprises are implemented depending on the nature or source of income. This dynamic book explores the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as acting as an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes.

Access to Treaty Benefits

Author : Desiree Auer
Publisher : Linde Verlag GmbH
ISBN 13 : 3709411610
Total Pages : 415 pages
Book Rating : 4.7/5 (94 download)

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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 415 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.

International Law of Taxation

Author : Peter Hongler
Publisher : Oxford University Press
ISBN 13 : 0192653903
Total Pages : 289 pages
Book Rating : 4.1/5 (926 download)

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Book Synopsis International Law of Taxation by : Peter Hongler

Download or read book International Law of Taxation written by Peter Hongler and published by Oxford University Press. This book was released on 2021-09-17 with total page 289 pages. Available in PDF, EPUB and Kindle. Book excerpt: In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.

Tax, Inequality, and Human Rights

Author : Philip G. Alston
Publisher : Oxford University Press
ISBN 13 : 0190882247
Total Pages : 496 pages
Book Rating : 4.1/5 (98 download)

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Book Synopsis Tax, Inequality, and Human Rights by : Philip G. Alston

Download or read book Tax, Inequality, and Human Rights written by Philip G. Alston and published by Oxford University Press. This book was released on 2019-04-11 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: For the first time, Human Rights and Tax in an Unequal World brings together works by human rights and tax law experts, to illustrate the linkages between the two fields and to reveal their mutual relevance in tackling economic, social, and political inequalities. Against the backdrop of systemic corporate tax avoidance, the widespread use of tax havens, persistent pressures to embrace austerity policies, and growing gaps between the rich and poor, this book encourages readers to understand fiscal policy as human rights policy, with profound consequences for the wellbeing of citizens around the world. The essays collected examine where the foundational principles of tax law and human rights law intersect and diverge; discuss the cross-border nature and human rights impacts of abusive practices like tax avoidance and evasion; question the role of states in bringing transparency and accountability to tax policies and practices; highlight the responsibility of private sector actors for the consequences of tax laws; and critically evaluate certain domestic tax rules through the lens of equality and non-discrimination. The contributing scholars and practitioners explore how an international human rights framework can anchor debates around international tax reform and domestic fiscal consolidation in existing state obligations. They address what human rights law requires of state tax policies, and what a state's tax laws and loopholes mean for the enjoyment of human rights within and outside its borders. Ultimately, tax and human rights both turn on the relationship between the individual and the state, and thus both fields face crises as the social contract frays and populist, illiberal regimes are on the rise.

International Tax Policy and Double Tax Treaties

Author : Kevin Holmes
Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis International Tax Policy and Double Tax Treaties by : Kevin Holmes

Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.