Residence Of Companies Under Tax Treaties And Ec Law
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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.
International And Ec Tax Aspects Of Groups And Companies
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Author : Guglielmo Maisto (jurist.)
language : en
Publisher: IBFD
Release Date : 2008
International And Ec Tax Aspects Of Groups And Companies 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 2008 with Corporations categories.
Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions.
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2012
Taxation Of Intercompany Dividends Under Tax Treaties And Eu 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 2012 with Corporations categories.
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation 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 dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Dual Residence In Tax Treaty Law And Ec Law
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Author : Matthias Hofstätter
language : en
Publisher:
Release Date : 2009
Dual Residence In Tax Treaty Law And Ec Law written by Matthias Hofstätter and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Domicile in taxation categories.
Eu Tax Law
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Author : Marjaana Helminen
language : en
Publisher: IBFD
Release Date : 2011
Eu Tax Law written by Marjaana Helminen 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 Direct taxation categories.
This book deals with all the EC law norms that are relevant from the perspective of direct taxes. It explains how these norms are, and should be, interpreted and how they affect national tax laws and the tax treatment in EU Member States. It begins by giving a comprehensive overview of the basic principles and concepts of EC tax law and all relevant articles of the EC Treaty, analysing them in the light of direct tax case law. A discussion follows covering all relevant EC directives and recommendations and other soft law material on direct taxes. Reference is made to all relevant judgments of the EC Court on direct taxes. The book includes a chapter on the tax treatment of the different EU entity forms and the future of corporate taxation, with a separate chapter dedicated to the EC law issues related to transfer pricing and to the EC law norms on administrative assistance in tax matters.
Tax Treaty Residence Of Entities
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Author : Jan Gooijer
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-09-13
Tax Treaty Residence Of Entities written by Jan Gooijer 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 2019-09-13 with Law categories.
It is of great importance to be able to determine who or what is considered ‘resident’ within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the ‘legalistic’ requirements for corporate residence. In this study of the OECD Model Tax Convention – the basis for most tax treaties – the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.
Residence Of Individuals Under Tax Treaties And Ec Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2010
Residence Of Individuals Under Tax Treaties And Ec 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 2010 with Domicile in taxation categories.
This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.
Cfc Legislation Tax Treaties And Ec Law
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2004-01-01
Cfc Legislation Tax Treaties And Ec Law written by Michael Lang 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 2004-01-01 with Law categories.
Compilation of 23 national reports dealing with domestic CFC provisions and the influence of tax treaties and EC law on CFC legislation and a summarising general report, originating from a joint conference on CFC legislation in Rust (Austria) from 3-6 July 2003.
The Impact Of Tax Treaties And Eu Law On Group Taxation Regimes
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Author : Bruno da Silva
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-07-11
The Impact Of Tax Treaties And Eu Law On Group Taxation Regimes written by Bruno da Silva 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 2016-07-11 with Law categories.
Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities – differences arising from the interaction of different tax systems – and obstacles – distortions created by domestic legislation arising from differences between domestic and cross-border situations – both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: – analysis of the different tax group regimes adopted by different countries; – advantages and disadvantages of a variety of models; – application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; – application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; – uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; – interrelations between tax treaties and EU Law in the context of tax groups; and – per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.
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.