Double Taxation Agreements

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Double Taxation Agreements

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Author : Philip Baker
language : en
Publisher:
Release Date : 1990

Double Taxation Agreements written by Philip Baker and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990 with Double taxation categories.

Introduction To The Law Of Double Taxation Conventions

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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-04-01

Introduction To The Law Of Double Taxation Conventions written by Michael Lang 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 2021-04-01 with Law categories.

The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.

Double Taxation Agreements

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Author : Pat O'Brien
language : en
Publisher:
Release Date : 1998

Double Taxation Agreements written by Pat O'Brien and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998 with Double taxation categories.

Indian Double Taxation Agreements Tax Laws 5th Ed

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Author : D P Mittal
language : en
Publisher:
Release Date : 2008-09-01

Indian Double Taxation Agreements Tax Laws 5th Ed written by D P Mittal and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-09-01 with Double taxation categories.

A Comprehensive and authentic Commentary on Indian Double Taxation Agreements with the help of decisions of International & Indian Courts as well as Authority for Advance Rulings * A comprehensive & critical study of UN Model Convention * Comparative and critical analysis of OECD Model Convention * Doing business with or in India, including e-business * Genesis and development of Treaty Models * Supremacy of a Tax Treaty over the domestic laws * Interpretation of a Tax Treaty * Classification of Income * Scope and purpose of a Tax Treaty * Taxes covered by a Treaty * Explaining definitions and expressions used in a tax treaty such as 'Resident', 'Permanent establishment', and others including 'Transfer pricing', 'Arm's length transactions', 'Treaty Shopping', etc. * Explaining expressions used in domestic tax laws but not defined in tax treaties such as Income (Real Income, Fictional Income, Substance over form). Total Income, Business, Profession, Computation of Income, etc. * Computation of income and distributive rules relating to income from Business, Shipping Business, Associates Enterprises, Capital Gains, Investment Income (dividends, interest, and royalties), Income from activities (personal and impersonal, pensions, directors' fee, entertainment, athletes, sports), Remuneration to students, etc. * Non-discrimination * Mutual agreement procedure for resolving disputes * Methods of eliminating Double Taxation, including Tax Sparing * Test of Double Taxation Agreements and Compendium of Relevant Circulars * Compendium of Rulings of Authority of Advance Rulings

Schwarz On Tax Treaties

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Author : Jonathan Schwarz
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-09-28

Schwarz On Tax Treaties written by Jonathan Schwarz 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 2021-09-28 with Law categories.

Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.

Double Taxation Treaties Between Industrialised And Developing Countries Oecd And Un Models

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Author : International Fiscal Association
language : en
Publisher: Springer
Release Date : 1992-05-18

Double Taxation Treaties Between Industrialised And Developing Countries Oecd And Un Models written by International Fiscal Association and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1992-05-18 with Business & Economics categories.

Proceedings of a seminar held in Stockholm in 1990 during the 44th Congress of the International Fiscal Association.

Singapore Tax Treaties

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Author :
language : en
Publisher:
Release Date : 1997

Singapore Tax Treaties written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1997 with Double taxation categories.

Principles And Practice Of Double Taxation Agreements

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Author : Robert Deutsch
language : en
Publisher:
Release Date : 2008

Principles And Practice Of Double Taxation Agreements written by Robert Deutsch and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Double taxation categories.

International Tax Policy And Double Tax Treaties

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Author : Kevin Holmes
language : en
Publisher: IBFD
Release Date : 2007

International Tax Policy And Double Tax Treaties written by Kevin Holmes and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Double taxation categories.

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.

Index To Double Taxation Agreements

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Author : Ronald Dibden
language : en
Publisher:
Release Date : 1968

Index To Double Taxation Agreements written by Ronald Dibden and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1968 with Double taxation categories.