Article 12b Un Model Convention 2021

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Article 12b Un Model Convention 2021

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Author : Christian Knotzer
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-07-15

Article 12b Un Model Convention 2021 written by Christian Knotzer 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 2024-07-15 with Law categories.

This groundbreaking book – a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy – provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for ‘Income from Automated Digital Services’. In extensive detail, the author thoroughly examines the article’s underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author’s analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book’s clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.

The Taxation Of Fees For Technical Services On The Basis Of Article 12a Un Model Convention

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Author : David Orzechowski-Zölzer
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2024-05-21

The Taxation Of Fees For Technical Services On The Basis Of Article 12a Un Model Convention written by David Orzechowski-Zölzer 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 2024-05-21 with Law categories.

Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and other allocation rules of the UN Model. The book’s analysis focuses on the interpretation of the concept of technical services by examining the historical evolution of Article 12 of the OECD and UN Models and the systematic context in which it is embedded. Aspects of this analysis examined include the following: the base-erosion principle as justification for establishing source taxing rights without the physical presence of the service provider in the state in which fees for technical services arise; whether the term ‘technical’ is sufficiently defined in the Commentaries to the UN Model or whether it shall be ascribed a different meaning to increase legal certainty for tax authorities and taxpayers; relevance of the OECD Model and its Commentaries as the basis for the UN Model and its Commentaries; rules of precedence concerning the application of Article 12A in relation to the other allocation rules of the UN Model; the connection between royalties and fees for technical services; application of Article 12A UN Model to challenges arising from the digitalized economy; and the allocation of taxing rights for fees for technical services rendered in a third state. Tax treaties of selected African countries are examined, as these countries were the earliest adopters of the concept of fees for technical services into their tax treaty network. The book also provides an overview of literature and jurisprudence on country practices in Brazil, India, and other countries, as well as relevant documents of international organizations. This book provides practitioners, government officials, and academics with a deep understanding of the interpretation and application of Article 12A UN Model. It will prove of great value in preparing for tax treaty negotiations and also in informing and advising enterprises that intend to conduct business in developing countries through the provision of specialized services.

Tax And Technology

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Author : Annika Streicher
language : en
Publisher: Linde Verlag GmbH
Release Date : 2023-10-13

Tax And Technology written by Annika Streicher 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 2023-10-13 with Law categories.

The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.

Article 12b Un Model Convention 2021

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Author : Christian Knotzer
language : en
Publisher:
Release Date : 2024-07-15

Article 12b Un Model Convention 2021 written by Christian Knotzer and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-07-15 with Law categories.

This groundbreaking book - a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy - provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for 'Income from Automated Digital Services'. In extensive detail, the author thoroughly examines the article's underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author's analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book's clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.

Tax Treaty Case Law Around The Globe 2023

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Author : Georg Kofler
language : en
Publisher: Linde Verlag GmbH
Release Date : 2024-04-17

Tax Treaty Case Law Around The Globe 2023 written by Georg Kofler 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 2024-04-17 with Law categories.

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 29 most important tax treaty cases that were decided around the world in 2022. 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 2023 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.

A Research Agenda For Tax Law

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Author : Parada, Leopoldo
language : en
Publisher: Edward Elgar Publishing
Release Date : 2022-10-11

A Research Agenda For Tax Law written by Parada, Leopoldo and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-10-11 with Law categories.

This Research Agenda considers the future direction of research in tax law, channeling creative thinking from leading tax scholars around the world who explore potential routes for further development in both traditional and more unconventional areas of tax law.

The Oxford Handbook Of International Law And Development

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Author : Ruth Buchanan
language : en
Publisher: Oxford University Press
Release Date : 2024-02-15

The Oxford Handbook Of International Law And Development written by Ruth Buchanan and has been published by Oxford University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-02-15 with Business & Economics categories.

The Oxford Handbook of International Law and Development is a unique overview of the field of international law and development, examining how normative beliefs and assumptions around development are instantiated in law, and critically examining disciplinary frameworks, competing agendas, legal actors and institutions, and alternative futures.

Ca Cma Final Direct Tax Question Bank For May June Nov Dec 2024

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Author : CA. Saket Ghiria
language : en
Publisher: Saket Ghiria Classes
Release Date : 2024-04-15

Ca Cma Final Direct Tax Question Bank For May June Nov Dec 2024 written by CA. Saket Ghiria and has been published by Saket Ghiria Classes this book supported file pdf, txt, epub, kindle and other format this book has been release on 2024-04-15 with Business & Economics categories.

A Comprehensive Question Bank for CA/CMA Final Direct Tax for May/June 24 & Nov/Dec 2024 Exams. Major Features a) Contains over 700 questions. b) Questions are non-repetitive in nature and covers a wide variety of concepts. c) One need through knowledge of the syllabus for attempting the questions. d) As far as possible, accuracy is ensured both in calculations as well as in provisions. e) Having questions on Tax Audit, Black Money Law and other Amendmends by FA 2023. Connect with us: ❤ Our YouTube Channel - https://www.youtube.com/@saketghiria ❤ Our Telegram Channel - https://t.me/sgccafinal ❤ Our Website - https://saketghiria.com

Radhakishan Rawal S Analysis Of The Finance Act 2021 And More

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Author : Radhakishan Rawal
language : en
Publisher: Bloomsbury Publishing
Release Date : 2021-06-30

Radhakishan Rawal S Analysis Of The Finance Act 2021 And More written by Radhakishan Rawal and has been published by Bloomsbury Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-06-30 with Law categories.

About this book This book contains detailed analysis of some of the key provisions of the Finance Act, 2021 with the objective of identifying various issues arising from the newly inserted provisions in the Income Tax Act, 1961. This book also captures the recent development in the world of international taxation. This includes UN tax developments and a very simple explanation of working of OECD Inclusive Frameworks Pillar One and Pillar Two blueprints, which are too complex and lengthy documents. From GST perspective, the book contains certain recommendations for rationalization of anti-profiteering provisions. The book also contains a Concept Paper on UN MLI presented by the author to the FACTI Panel and G77. The author has been pushing this idea at international forums for some time. Key Features Analysis of provisions related to: · Liable to tax · Slump sale · MAT · Taxation of ULIPS · Equalisation Levy · Amendment to SCRA · Section 89A · Concept of UN MLI · OECD Pillar One and Two Blueprint · India comments on OECD Commentary · Covid 19 and International Tax · Scope of option u/s 90(2) – Selective claim of treaty benefit · Scope of PE under the domestic law · UN Developments – Royalties, Indirect transfer and CIVs · Rationalisation of anti-profiteering provisions (GST law)

International Corporate Tax Reform

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Author : International Monetary
language : en
Publisher: International Monetary Fund
Release Date : 2023-02-06

International Corporate Tax Reform written by International Monetary and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023-02-06 with Business & Economics categories.

To relieve the pressure on the outdated international corporate tax system, an ambitious reform was agreed at the Inclusive Framework (IF) on Base Erosion and Profit Shifting in 2021, with now 138 jurisdictions joining. It complements previous efforts to mitigate profit shifting by addressing the challenges of the digitalization of the economy through a new allocation of taxing rights to market economies (Pillar 1) and tax competition through a global minimum corporate tax (Pillar 2). This paper concludes that the agreement makes the international tax system more robust to tax spillovers, better equipped to address digitalization, and modestly raises global tax revenues.