Model Income Tax Treaties
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Model Income Tax Treaties
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Author : Kees van Raad
language : en
Publisher: Springer
Release Date : 2013-06-29
Model Income Tax Treaties written by Kees van Raad and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-06-29 with Business & Economics categories.
In this booklet a comparative survey is offered offour model income tax conventions: the OECD drafts of 1963 and 1977, the United Nations Model of 1980 and the proposed United States Treasury's model of 1981. In order to facilitate the compari son, the text of the 1977 OECD draft is used as reference. Additions and alternatives in any of the other models to this 1977 OECD text are italicized. Omissions from the 1977 OECD model in the other drafts are indicated either by a blank space (where an entire paragraph has been suppressed) or by brackets [] ( in case of smaller omissions). The Hague, May 1983 Kees van Raad OECD 1963 OECD 1977 OECD DRAFT DOUBLE TAXA OECD MODEL DOUBLE TAXA TION CONVENTION ON INCOME TION CONVENTION ON INCOME AND CAPITAL AND CAPITAL 1963 1977 TITLE[] TITLE OF THE CONVENTION Convention between (State A) and (State Convention between (State A) and (State B) for the avoidance of double taxation B) for the avoidance of double taxation with respect to taxes on income and on with respect to taxes on income and m capital capital 1 PREAMBLE OF THE CONVENTION CHAPTER I CHAPTER I SCOPE OF THE CONVENTION SCOPE OF THE CONVENTION Article 1 Article 1 PERSONAL SCOPE PERSONAL SCOPE This Convention shall apply to persons This Convention shall apply to persons who are residents of one or both of the who are residents of one or both of the Contracting States. Contracting States.
Model Income Tax Treaties
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Author : Cornelis Raad
language : en
Publisher: Kluwer Academic Publishers
Release Date : 1983
Model Income Tax Treaties written by Cornelis Raad and has been published by Kluwer Academic Publishers this book supported file pdf, txt, epub, kindle and other format this book has been release on 1983 with Business & Economics categories.
In this booklet a comparative survey is offered offour model income tax conventions: the OECD drafts of 1963 and 1977, the United Nations Model of 1980 and the proposed United States Treasury's model of 1981. In order to facilitate the compari son, the text of the 1977 OECD draft is used as reference. Additions and alternatives in any of the other models to this 1977 OECD text are italicized. Omissions from the 1977 OECD model in the other drafts are indicated either by a blank space (where an entire paragraph has been suppressed) or by brackets [] ( in case of smaller omissions). The Hague, May 1983 Kees van Raad OECD 1963 OECD 1977 OECD DRAFT DOUBLE TAXA OECD MODEL DOUBLE TAXA TION CONVENTION ON INCOME TION CONVENTION ON INCOME AND CAPITAL AND CAPITAL 1963 1977 TITLE[] TITLE OF THE CONVENTION Convention between (State A) and (State Convention between (State A) and (State B) for the avoidance of double taxation B) for the avoidance of double taxation with respect to taxes on income and on with respect to taxes on income and m capital capital 1 PREAMBLE OF THE CONVENTION CHAPTER I CHAPTER I SCOPE OF THE CONVENTION SCOPE OF THE CONVENTION Article 1 Article 1 PERSONAL SCOPE PERSONAL SCOPE This Convention shall apply to persons This Convention shall apply to persons who are residents of one or both of the who are residents of one or both of the Contracting States. Contracting States.
Model Income Tax Treaties
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Author : Cornelis Raad
language : en
Publisher: Springer
Release Date : 1990-10-02
Model Income Tax Treaties written by Cornelis Raad and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990-10-02 with Business & Economics categories.
Model Income Tax Treaties
U S Income Tax Treaties
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Author : Richard L. Doernberg
language : en
Publisher:
Release Date : 1999
U S Income Tax Treaties written by Richard L. Doernberg and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999 with Double taxation categories.
Text originally prepared for a class. Includes course outline, assignments and supporting materials.
United States Income Tax Treaties
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Author : Klaus Vogel
language : en
Publisher: Springer
Release Date : 1989
United States Income Tax Treaties written by Klaus Vogel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 1989 with Law categories.
Comprehensive loose-leaf guide analysing United States income tax treaties. The commentary is divided into three parts providing general background information regarding income tax treaties and the model treaty process, commentary of the individual provisions of the US Model and of existing US treaties, appendices are included.
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.
Taxes Covered
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Author : Patricia Brandstetter
language : en
Publisher: IBFD
Release Date : 2011
Taxes Covered written by Patricia Brandstetter and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Capital levy categories.
"The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ('Taxes covered') of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpetive issues and uncertainties in practical treaty application. This book not only provides in-depth analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of today's tax treaties. The source documents used have rarely found their way into publications before: historical OEEC and OECD Reports and Minutes, originally largely classified as 'restricted' and thus inaccessible to the public for decades, provide an insight into the drafting process of Art. 2 and the discussions of Delegates from various nations on practical implications for treaty application. The book offers a unique perspective on this core treaty provision and aims to provide guidance for determing the 'taxes covered' in any tax treaty"--Page 4 of cover.
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...
Income Tax Treaties
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Author : Jon E. Bischel
language : en
Publisher:
Release Date : 1978
Income Tax Treaties written by Jon E. Bischel and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1978 with Double taxation categories.
Compilation of studies in the field of international taxation in United States bilateral tax treaties with other countries (the United Kingdom, France, Germany and Japan) as well as a description of structure and operation of tax treaties in general.
Model Income Tax Treaties
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Author : Kees Van Raad
language : en
Publisher:
Release Date : 1990
Model Income Tax Treaties written by Kees Van Raad and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1990 with categories.