Issues In International Taxation Issues Related To Article 14 Of The Oecd Model Tax Convention
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Issues In International Taxation Issues Related To Article 14 Of The Oecd Model Tax Convention
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2000-04-01
Issues In International Taxation Issues Related To Article 14 Of 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 2000-04-01 with categories.
This book recommends that Article 14 be eliminated from the OECD Model Tax Convention and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence.
Issues In International Taxation Issues Related To Article 14 Of The Oecd Model Tax Convention
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Author :
language : en
Publisher:
Release Date : 2000
Issues In International Taxation Issues Related To Article 14 Of The Oecd Model Tax Convention written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2000 with categories.
Issues In International Taxation The Application Of The Oecd Model Tax Convention To Partnerships
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1999-08-26
Issues In International Taxation The Application Of The Oecd Model Tax Convention To Partnerships 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 1999-08-26 with categories.
This report addresses the issue of the application of tax treaties to cases involving partnerships in detail and focuses on specific factual examples.
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.
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, ...
Model Tax Convention On Income And On Capital 2014 Full Version
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2015-10-30
Model Tax Convention On Income And On Capital 2014 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 2015-10-30 with categories.
This publication is the ninth 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 on Income and on Capital as it read on 15 July 2014.
Issues In International Taxation Model Tax Convention Four Related Studies
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1992-12-23
Issues In International Taxation Model Tax Convention Four Related Studies 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 1992-12-23 with categories.
This publication, includes four recent reports of the Committee on Fiscal Affairs that have resulted in changes to the Commentary of the Model Tax Convention on Income and on Capital.
The Legal Status Of The Oecd Commentaries
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Author : Sjoerd Douma
language : en
Publisher: IBFD
Release Date : 2008
The Legal Status Of The Oecd Commentaries written by Sjoerd Douma and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Double taxation categories.
Since the mid-1980s, the legal basis of the practice of tax administrations and courts around the world to conform to the Commentaries when interpreting and applying bilateral tax treaties based on the OECD Model has been the subject of an ongoing academic debate. Recently the debate has received new impetus, and the primary focus is now on the general principles of international law. In particular, opinions differ on the question whether the Commentaries can be a source of legal obligations through the principles of acquiescence and estoppel, both of which are founded on considerations of good faith, and equity and provide specific protection of settled expectations. The reports contained in this book address two questions. The first is whether, under international law, the states parties to a tax treaty are legally bound by the OECD Commentaries when interpreting and applying the provisions of the treaty which are identical to those of the OECD Model. The second question is whether, under the contracting states' internal law, taxpayers and the tax authorities are equally bound to apply the Commentaries if and when the contracting states themselves are so bound under international law. The book brings various legal disciplines - public international law, international tax law, Community law and constitutional law - together in order to resolve the legal status of the Commentaries. Through interdisciplinary debate, the issues have been defined clearly and the exact points at which the opinions differ are identified, thereby resulting in a better understanding of the issues at hand.
Other Income Under Tax Treaties
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Author : Alexander Bosman
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2015-09-23
Other Income Under Tax Treaties written by Alexander Bosman 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 2015-09-23 with Law categories.
Bilateral tax treaties are often, to a greater or lesser extent, based on the OECD Model Convention. Among the distributive rules with respect to taxation of income which are laid down in Chapter III of that model, Article 21 assigns the tax jurisdiction in respect of "other income" - understood to mean items of income which are not dealt with in other provisions of the tax treaty - to the residence state in accordance with the main rule underlying the OECD Model, thus ensuring that no income falls outside the scope of the treaty. This study provides a comprehensive analysis of Article 21 of the OECD Model. In extensive detail, and with reference to case law from a number of jurisdictions and to statements of various authorities and official documents, the author shows how Article 21 operates in relation to the other distributive rules of the OECD Model and bilateral tax treaties based thereon. The analysis considers such items of income as the following in relation to Article 21: - income from immovable property; - business profits; - profits from shipping, inland waterways transport, and air transport; - dividends, interest, and royalties; - capital gains; and - income from employment. In addition, the author examines the significance of the OECD Commentaries for the interpretation of tax treaties, the "other income" article in other model conventions, and notable deviations from Article 21 among bilateral tax treaties. An appendix offers well-grounded recommendations on how to potentially amend the wording of Article 21 and the related commentary and how the application of the article can be improved. Although underexposed in the tax law literature heretofore, the "other income" article raises important international taxation issues that remain problematic or unresolved. Tax lawyers, government officials, and other interested professionals will find here a penetrating analysis that goes a long way towards clarifying the characterisation of income that resists the standard categories defined in tax treaties.