Immovable Property Under Domestic Law Eu Law And Tax Treaties
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Immovable Property Under Domestic Law Eu Law And Tax Treaties
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Author : Guglielmo Maisto
language : en
Publisher:
Release Date : 2015
Immovable Property Under Domestic Law Eu Law And Tax Treaties written by Guglielmo Maisto and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with categories.
This book, comprising the proceedings and working documents of an annual seminar held in Milan in November 2014, provides a thorough analysis of the taxation of immovable properties. 0The analysis starts from a survey of the concept of “immovable property” in common and civil law jurisdictions and then considers how different approaches affected the taxation of income deriving therefrom. 0EU tax law issues are then taken into consideration, both from an income tax and VAT viewpoint. In particular, the income tax analysis provides an extensive examination of how taxation of immovable property applied by EU Member States may affect fundamental freedoms.
Taxation Of Intellectual Property Under Domestic Law Eu Law And Tax Treaties
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Author : Guglielmo Maisto
language : en
Publisher:
Release Date : 2018
Taxation Of Intellectual Property Under Domestic Law Eu Law And Tax Treaties written by Guglielmo Maisto and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with categories.
Taxation of Intellectual Property under Domestic Law, EU Law and Tax Treaties, comprising the proceedings and working documents of an annual seminar held in Milan in November 2017, is a detailed and comprehensive study on the taxation of intellectual property (IP). It begins with a comparative analysis of the domestic private law aspects of IP and the domestic tax regimes applicable to profits deriving from the utilization of IP. It next examines the taxation of IP under EU law, with a particular emphasis on (i) the EU fundamental freedoms and State aid, and (ii) the open issues in the implementation of the EU Interest and Royalty Directive. The book then moves to selected tax treaty issues. In particular, it analyses (i) the historical background and the policy of article 12 of the OECD Model Convention; (ii) the meaning of "royalties" and overlapping between articles 7, 12 and 13 of the OECD Model Convention; (iii) royalties in the context of the OECD Multilateral Instrument under the limitation on benefits (LoB) provision and the principal purpose test (PPT) clause; and (iv) certain selected issues on cross-border transfers of IP. Individual country surveys provide an in-depth analysis of the domestic tax regimes and actual tax treaty application and practices by various states, including Australia, Austria, Brazil, Canada, China (People's Rep.), France, Germany, Italy, the Netherlands, Spain, Switzerland, the United Kingdom and the United States.
Taxation Of Intellectual Property Under Domestic Law Eu Law And Tax Treaties
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Author : Guglielmo Maisto
language : en
Publisher:
Release Date : 2020
Taxation Of Intellectual Property Under Domestic Law Eu Law And Tax Treaties written by Guglielmo Maisto and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020 with Intellectual property categories.
Taxation Of Intellectual Property Under Domestic Law Eu Law And Tax Treaties
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Author : Guglielmo Maisto
language : en
Publisher:
Release Date : 2018
Taxation Of Intellectual Property Under Domestic Law Eu Law And Tax Treaties written by Guglielmo Maisto and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with categories.
Tax Treaties And Domestic Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2006
Tax Treaties And Domestic Law written by Guglielmo Maisto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with Double taxation categories.
This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Europe China Tax Treaties
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Author : Jianwen Liu
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2010-05-28
Europe China Tax Treaties written by Jianwen Liu 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 2010-05-28 with Law categories.
The book is the result of a joint research project on the tax treaties concluded between the People’s Republic of China and European countries. Each chapter carefully analyses the extent to which Chinese tax treaties follow the OECD Model Tax Convention on Income and Capital and the UN Income and Capital Model Convention. The focus is on the different policy decisions underlying the various provisions. Additionally, the contributions analyse the extent to which Chinese tax treaty policy differs with respect to EU and non-EU Member States. They also highlight relevant policy changes over time. The fact that each contribution is the product of the collaboration between European and Chinese researchers and includes the results of the International Conference on Europe - China Tax Treaties Research, held in March 2009 in Beijing, serves to enrich its analysis. Among the topics covered are the following: • Treaty Entitlement (Articles 1, 4 and 24 OECD Model) • Business Profits (Articles 5, 6, 7, 8, 9, and 14 OECD Model) • Passive Income (Articles 10, 11, and 12 OECD Model) • Capital Gains (Article 13 OECD Model) • Employment Income (Articles 15, 16, 18, 19, and 20 OECD Model) • Artistes and Sportsmen (Article 17 OECD Model) • Methods to Avoid Double Taxation (Article 23 OECD Model) • Non-Discrimination (Article 24 OECD Model) • Mutual Agreement, Exchange of Information and Mutual Assistance in the Collection of Taxes (Articles 25, 26 and 27 OECD Model)
Taxation Of Companies On Capital Gains On Shares Under Domestic Law Eu Law And Tax Treaties
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Author :
language : en
Publisher:
Release Date : 2013
Taxation Of Companies On Capital Gains On Shares Under Domestic Law Eu Law And 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 2013 with categories.
This book is a comprehensive study on the taxation of capital gains on shares derived by companies. The book begins by discussing the trends in the taxation of capital gains on shares under domestic law, taking into account the input from various national reports. It then considers the taxation of capital gains on shares in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of capital gains on shares and the possible impact of the EU income tax directives are examined. Next, the book discusses the taxation of capital gains on shares under tax treaties. The focus initially is on the notion of "capital gains on shares" in the OECD Model Convention and the qualification conflicts possibly arising in this respect. In addition, attention is also devoted to tax treaty aspects of company reorganizations that could trigger taxation of capital gains on shares and to tax treaty provisions regarding shares attributable to permanent establishments and non-discrimination. Finally, the application of domestic and agreement-based anti-abuse rules to transfers of shares is thoroughly analysed, with an eye also on recent rules and doctrines aimed at taxing indirect transfers. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in North America, selected European jurisdictions, Australia, China and India.
Investment Fund Taxation
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Author : Werner Haslehner
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2017-04-24
Investment Fund Taxation written by Werner Haslehner 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 2017-04-24 with Law categories.
The effect of the significant changes in tax law at domestic, European, and international levels on investment funds, an important part of global financial services, creates a complex environment for practitioners and a source of debate for academics and policymakers. This is the first book to provide a comprehensive legal and practical analysis of the changes to the complex multilevel tax and regulatory framework concerning different types of investment funds. The contributions, updated as of late 2017, were originally presented at a conference held at the University of Luxembourg in November 2016 under the auspices of the ATOZ Chair for European and International Taxation. The book covers the central questions arising in national law and tax policy, explores the regulatory and tax framework of the European Union (EU), and discusses the multifaceted interactions of both national and EU law with bilateral tax treaties. Through fourteen chapters following a brief introduction, leading academic experts and practising specialists provide decisive insight into: – the regulatory regime for European investment funds; – the tax law and reforms in both Luxembourg and Germany; – the role of the European Commission’s State-aid practices; – examples of case law concerning the application of non-discrimination rules to various investment vehicles; – the impact of tax-specific EU legislation, such as the Parent-Subsidiary Directive, the Tax Merger Directive, and the Anti-Tax Avoidance Directive; – the availability of tax treaty protection for different collective and non-collective investment funds; – the impact of base erosion and profit shifting (BEPS) developments on the taxation of cross-border investments; – the value-added tax (VAT) treatment of investment funds and their managers; and – the consequences of the global drive towards automatic exchange of information relating to existing cross-border investment structures. With its particular focus on Luxembourg – the leading centre for investment funds in Europe (and second only to the United States globally) and, thus, an instructive model for domestic-level investment fund regulation and taxation – this volume reveals the common issues that arise in virtually every other jurisdiction with a sizeable fund industry. As the first in-depth treatment of the globally significant nexus between investment funds and taxation, the book will prove valuable to policymakers, practitioners, and academics in both financial services and tax law.
Residence Of Companies Under Tax Treaties And Ec Law
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Author : Guglielmo Maisto (jurist.)
language : en
Publisher: IBFD
Release Date : 2009
Residence Of Companies Under Tax Treaties And Ec Law written by Guglielmo Maisto (jurist.) and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Business enterprises categories.
Deals with issues and problems raised by residence of companies for tax purposes, including detailed analysis from a national viewpoint in selected European and North American jurisdictions, Australia and South Africa.
Courts And Tax Treaty Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2007
Courts And Tax Treaty Law written by Guglielmo Maisto 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 Courts categories.
A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.