Introduction To The Law Of Double Taxation Conventions
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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 And The League Of Nations
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Author : Sunita Jogarajan
language : en
Publisher: Cambridge University Press
Release Date : 2018-05-10
Double Taxation And The League Of Nations written by Sunita Jogarajan and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-05-10 with Law categories.
Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
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...
International Taxation Of Permanent Establishments
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Author : Michael Kobetsky
language : en
Publisher: Cambridge University Press
Release Date : 2011-09-15
International Taxation Of Permanent Establishments written by Michael Kobetsky and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-09-15 with Law categories.
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
International Tax Policy
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Author : Tsilly Dagan
language : en
Publisher: Cambridge University Press
Release Date : 2018
International Tax Policy written by Tsilly Dagan and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with Business & Economics categories.
Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.
Interpretation And Application Of Tax Treaties In North America
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Author : Juan Angel Becerra
language : en
Publisher: IBFD
Release Date : 2007
Interpretation And Application Of Tax Treaties In North America written by Juan Angel Becerra 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 Canada categories.
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Non Discrimination In Tax Treaty Law And World Trade Law
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Author : Kasper Dziurdz
language : en
Publisher: International Taxation
Release Date : 2019-07-23
Non Discrimination In Tax Treaty Law And World Trade Law written by Kasper Dziurdz and has been published by International Taxation this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-07-23 with Law categories.
Non-discrimination is a central obligation under both tax treaty and trade law. However, in seeking to strike a balance between national and international interests, its application differs in the two areas of practice. This deeply researched and authoritative work, which explains the policy issues and how non-discrimination analysis works, provides a comprehensive review of non-discrimination rules in WTO and tax treaty law, combining a critical commentary on case law with proposals for an innovative concept for solving cases of discrimination in tax treaty law. Among the practical issues affecting non-discrimination examined in detail are the following: implications that can be drawn from the concepts of non-discrimination under WTO law and Article 24 of the OECD Model; direct and indirect discrimination and analysis of comparability in WTO law and tax treaty law; the MFN and NT rules under the GATT and GATS; the meaning of 'likeness' and 'less favourable treatment'; claiming non-discriminatory tax treatment before tax administrations and courts under a tax treaty; justification of measures against harmful tax competition, low taxation and hybrid mismatch arrangements; thin capitalisation rules, progressive tax rates, foreign losses, group taxation and relief from juridical and economic double taxation under Article 24 of the OECD Model; and integrating a justification defence into any stage of a non-discrimination analysis. The author establishes to what extent formal, substantive and subjective approaches may be applied in a non-discrimination analysis, providing the reasons for the approaches taken. A two-step comparability procedure is applied to selected cases of potential tax discrimination, demonstrating how policy arguments can be addressed under Article 24 of the OECD Model. Drawing on over a half-century of case law in both areas of practice, this comprehensive study of the non-discrimination rules under WTO law and international tax law will be invaluable in systematically solving cases of tax discrimination under Article 24 of the OECD Model and putting forward arguments at any stage of a WTO analysis. Policymakers will benefit from the author's clear explanation of how national law should comply with international obligations. Also, taxpayers' advisers will proceed confidently in claims of tax treaty discrimination, and academics will discover an incomparable overview and analysis of anti-discrimination rules in international trade law and double taxation conventions.
International Exchange Of Information In Tax Matters
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Author : Xavier Oberson
language : en
Publisher: Edward Elgar Publishing
Release Date :
International Exchange Of Information In Tax Matters written by Xavier Oberson 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 with Disclosure of information categories.
The financial crisis of 2008 and the emergence of various scandals around the world sparked a movement towards greater transparency with international exchange of information in tax matters. Fully revised and updated, this book considers the emergence of a new global standard, the automatic exchange of information. Providing a comprehensive overview of the main developments, it analyses the structure and content of the various existing instruments and models, taking into account the most up to date developments.
Research Handbook On International Taxation
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Author : Yariv Brauner
language : en
Publisher: Edward Elgar Publishing
Release Date : 2020-12-25
Research Handbook On International Taxation written by Yariv Brauner 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 2020-12-25 with Law categories.
Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Introduction To The Law Of Double Taxation Conventions
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Author : M. Lang
language : en
Publisher:
Release Date : 2013
Introduction To The Law Of Double Taxation Conventions written by M. Lang 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.
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 book provides an introduction to the law of double taxation conventions. Through examples from different countries and their jurisdictions, the book gives a global overview. 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 are also discussed in detail. Finally, the book analyses all provisions of the OECD and UN Model Tax Conventions on Income and on Capital and the OECD Model Convention on Estate, Inheritance and Gift Tax.