Access To Treaty Benefits
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Access To Treaty Benefits
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Author : Desiree Auer
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-09-21
Access To Treaty Benefits written by Desiree Auer and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-09-21 with Law categories.
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.
Access To Treaty Benefits
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Author : Desiree Auer
language : en
Publisher:
Release Date : 2021
Access To Treaty Benefits written by Desiree Auer and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021 with categories.
Limitation On Benefits Clauses In Double Taxation Conventions
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Author : Félix Alberto Vega Borrego
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
Limitation On Benefits Clauses In Double Taxation Conventions written by Félix Alberto Vega Borrego and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-24 with Law categories.
Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Schwarz On Tax Treaties
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Author : Jonathan Schwarz
language : en
Publisher:
Release Date : 2009
Schwarz On Tax Treaties written by Jonathan Schwarz and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Double taxation categories.
United States Tax Treaties
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Author : United States
language : en
Publisher: Springer
Release Date : 1991-02-05
United States Tax Treaties written by United States and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1991-02-05 with Business & Economics categories.
This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.
Model Tax Convention On Income And On Capital Condensed Version 2017
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-12-18
Model Tax Convention On Income And On Capital Condensed Version 2017 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-12-18 with categories.
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
Model Tax Convention On Income And On Capital 2017 Full Version
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2019-04-25
Model Tax Convention On Income And On Capital 2017 Full Version written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-04-25 with categories.
This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Unraveling The Nagoya Protocol
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Author : Elisa Morgera
language : en
Publisher: Martinus Nijhoff Publishers
Release Date : 2014-07-25
Unraveling The Nagoya Protocol written by Elisa Morgera and has been published by Martinus Nijhoff Publishers this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-07-25 with Law categories.
The Nagoya Protocol is an unprecedented international environmental agreement that equally addresses development, distributive justice, and environmental sustainability. With a balanced view of the various possible interpretations of the Protocol provisions, in light of different national and regional perspectives, and a systematic highlighting of its legal innovations, Unraveling the Nagoya Protocol: A Commentary on the Nagoya Protocol on Access and Benefit-sharing to the Convention on Biological Diversity will serve as a seminal work for all those interested in the environment, human rights, economics and both legal and scientific innovations.
Main Provisions And Benefits Of The Marrakesh Treaty 2013
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Author : World Intellectual Property Organization
language : en
Publisher: WIPO
Release Date : 2016-05-26
Main Provisions And Benefits Of The Marrakesh Treaty 2013 written by World Intellectual Property Organization and has been published by WIPO this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-05-26 with Law categories.
This leaflet explains how the Marrakesh Treaty works and why it is so important.
Issues In International Taxation 2002 Reports Related To The Oecd Model Tax Convention
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2003-05-16
Issues In International Taxation 2002 Reports Related To The Oecd Model Tax Convention written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003-05-16 with categories.
This publication includes three recent reports that resulted in changes to the OECD Model Tax Convention. One covers entitlement to treaty benefits, another covers e-commerce, and the third covers issues arising under the permanent establishment article.