Pending Bilateral Tax Treaties And Oecd Tax Convention
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Pending Bilateral Tax Treaties And Oecd Tax Convention
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Author : United States. Congress. Senate. Committee on Foreign Relations
language : en
Publisher:
Release Date : 1990
Pending Bilateral Tax Treaties And Oecd Tax Convention written by United States. Congress. Senate. Committee on Foreign Relations 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.
Pending Bilateral Tax Treaties And Oecd Tax Convention
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Author : United States. Congress. Senate. Committee on Foreign Relations
language : en
Publisher:
Release Date : 1990
Pending Bilateral Tax Treaties And Oecd Tax Convention written by United States. Congress. Senate. Committee on Foreign Relations 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.
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.
Multilateral Tax Treaties
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Author : Helmut Loukota
language : en
Publisher: Kluwer Law International B.V.
Release Date : 1998-04-22
Multilateral Tax Treaties written by Helmut Loukota 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 1998-04-22 with Business & Economics categories.
The book is a result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed analysis of the arguments for and against the conclusion of a multilateral tax treaty, and of the various European law issues that arise in this context.
Permanent Establishments
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Author : Ekkehart Reimer
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-06-07
Permanent Establishments written by Ekkehart Reimer 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 2018-06-07 with Law categories.
Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.
The Application Of The Oecd Model Tax Convention To Partnerships
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Author : Organisation for Economic Co-operation and Development
language : en
Publisher: Org. for Economic Cooperation & Development
Release Date : 1999
The Application Of The Oecd Model Tax Convention To Partnerships written by Organisation for Economic Co-operation and Development and has been published by Org. for Economic Cooperation & Development this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999 with Business & Economics categories.
The book includes the report adopted by Committee on Fiscal Affairs. It deals with the application of the provisions of the OECD Model Tax Convention, and indirectly of bilateral tax conventions based on that Model, to the partnerships. It includes the reservations of France, Germany, the Netherlands, Portugal and Switzerland on various aspects of the report.
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.
A Multilateral Convention For Tax
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Author : Sergio André Rocha
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-11-29
A Multilateral Convention For Tax written by Sergio André Rocha 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 2021-11-29 with Law categories.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.
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.
Taxation Of Bilateral Investments
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Author : Carlo Garbarino
language : en
Publisher: Edward Elgar Publishing
Release Date : 2019
Taxation Of Bilateral Investments written by Carlo Garbarino 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 2019 with Corporations categories.
The OECD’s guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.