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Taxation Of International Performing Artistes


Author : Dick Molenaar
language : en
Publisher: IBFD
Release Date : 2006

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Judicial Interpretation Of Tax Treaties


Author : Carlo Garbarino
language : en
Publisher: Edward Elgar Publishing
Release Date : 2016-10-28

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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.

Europe China Tax Treaties


Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2010-01-01

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This network aims at initiating and coordinating both comparative education in taxation, through the organisation of activities such as winter courses and guest lectures, and comparative research in the field, by means of joint research projects, international conferences and exchange of researchers between various countries. --

Ibfd International Tax Glossary


Author : Julie Rogers-Glabush
language : en
Publisher: IBFD
Release Date : 2009

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Global Trends In Vat Gst And Direct Taxation


Author : Sebastian Pfeiffer
language : en
Publisher: Linde Verlag GmbH
Release Date : 2015-08-11

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Recent developments in direct taxes and VAT/GST Taxes – in general – have become the topic of broad legal and policy discussions. VAT and GST are often said to be the fiscal success story of the 20th century, as almost all developed countries levy VAT or GST or similar all-encompassing broad-based consumption taxes. Global trends in direct taxes are visible at the level of international players, such as the OECD. Due to the OECD’s BEPS project, national tax systems are being significantly modified. This book aims at identifying and discussing the current global trends in both VAT/GST and direct taxes. In daily practice, VAT/GST and direct taxes should be regarded simultaneously. Therefore, the Master’s theses contained in this book deal with and highlight numerous issues, challenges and opportunities found in both direct taxes and in the VAT/GST area, ranging from nexus in direct taxes and VAT/GST, recent developments in certain policy areas, the definition of taxable persons, tax abuse, non-discrimination rules, charities, transfer pricing, European State aid, immovable property, share deals etc. While the construction of VAT/GST and direct taxes differs, both taxes have similarities. The contributions in this book make a legal comparison of the recent developments in direct taxes and VAT/GST in the relevant fields, provide an analysis of the similarities and differences of the two taxation systems and highlight global trends in taxation.

Source Versus Residence


Author : Michael Lang
language : en
Publisher:
Release Date : 2008

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One of the major objectives of tax treaties has been the avoidance of international double taxation. This is generally accomplished through the agreement of each country to limit, in specified situations set out in double tax treaties, its right to tax income earned from its territory by residents of another country. The OECD Model Tax Treaty, other model conventions, and the bilateral treaties drafted in accordance with these models, allocate the taxing rights between the state of source and the state of residence. The source rules for income taxation are determined by Articles 6 through 21 of the OECD Model Convention. These rules are the product of a rather long history and it seems difficult to justify the scope of some in todayand’s world. Courts, tax administrators, and practitioners are confronted with a growing number of interpretation and application problems. In a globalized world with ever-increasing cross-border streams of income such problems command more and more attention. This book is designed to analyze the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The distinguished contributors to the work examine the justification for these rules - as well as their scope and– and highlight the most relevant interpretation and attendant application problems. In addition theyand’ll suggest how such rules should be modified and examine possible alternatives.

Bulletin For International Taxation


Author :
language : en
Publisher:
Release Date : 2009

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