The Improper Use Of Tax Treaties With Particular Reference To The Netherlands And The United States
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The Improper Use Of Tax Treaties With Particular Reference To The Netherlands And The United States
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Author : Stef Weeghel
language : en
Publisher: Kluwer Law International B.V.
Release Date : 1998-03-27
The Improper Use Of Tax Treaties With Particular Reference To The Netherlands And The United States written by Stef Weeghel 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 1998-03-27 with Business & Economics categories.
"With particular reference to the Netherlands and the United States."--T.p.
Preventing Treaty Abuse
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Author : Daniel Blum
language : en
Publisher: Linde Verlag GmbH
Release Date : 2016-09-19
Preventing Treaty Abuse written by Daniel Blum 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 2016-09-19 with Law categories.
Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.
Concept And Implementation Of Cfc Legislation
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Author : Nathalie Bravo
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-09-21
Concept And Implementation Of Cfc Legislation written by Nathalie Bravo 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 2021-09-21 with Law categories.
An in-depth analysis of various aspects of CFC legislation This volume provides an in-depth analysis of various aspects of the topic “Concept and Implementation of CFC legislation”. The volume is divided into four parts. The first part comprises chapters discussing the historical background, policy considerations, and different CFC approaches that have been implemented in domestic legislation. While the chapters included in the second part focus on the recommendation for the effective design of CFC rules found in BEPS Action 3, the chapters encompassed in the third part analyse the implementation of these criteria in Articles 7 and 8 of the ATAD and the compatibility of these provisions with EU primary law. Finally, the chapters encompassed in part four deal with selected issues related to CFC rules, including the compatibility of CFC legislation and tax treaties, the relationship between these rules and general anti-abuse rules, the implications of the proposed CCCTB Directive on CFC rules, alternative approaches to CFC legislation (such as the Global Anti-Base Erosion proposal of the OECD/G20), the interrelationship between CFC rules and transfer pricing legislation, and the balance between effective CFC rules and compliance burdens.
Interpretation Of Tax Treaties Under International Law
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Author : F. A. Engelen
language : en
Publisher: IBFD
Release Date : 2004
Interpretation Of Tax Treaties Under International Law written by F. A. Engelen and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004 with Double taxation categories.
This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).
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.
Beneficial Ownership In International Taxation
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Author : Kuźniacki, Błażej
language : en
Publisher: Edward Elgar Publishing
Release Date : 2022-08-12
Beneficial Ownership In International Taxation written by Kuźniacki, Błażej 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 2022-08-12 with Law categories.
This authoritative book provides a structural, global view of evolving judicial and doctrinal trends in the understanding of beneficial ownership in international taxation. Błażej Kuźniacki presents a route towards an international autonomous meaning of beneficial ownership, while also offering a comprehensive explanation of the divergent understandings and tax policy arguments underpinning its continuing ambiguity.
Tax Treaties Building Bridges Between Law And Economics
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Author :
language : en
Publisher: IBFD
Release Date : 2010
Tax Treaties Building Bridges Between Law And Economics written by 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 Double taxation categories.
In this book experts from the field of economics take a different view of tax treaty issues than experts from the field of law. In order to encourage the much needed communication between these two groups, a cross-disciplinary conference was held to discuss selected tax treaty issues from both a legal and economic perspective. Twenty-five conference papers on eight topics were prepared by lawyers and economists. The papers on legal issues were presented and discussed by economists, and vice versa. The interdisciplinary focus of the conference not only allowed an exchange of knowledge between two groups who think differently about similar issues, but also made it possible to better grasp the impact of the thinking of one group on the areas of interest to the other group. The outcome of the conference is reflected in this book. By showing the legal and the economic approaches to an issue, this book improves the general understanding of the two disciplines and demonstrates how the decisions in one discipline may influence the other discipline and its concepts. Twenty-two contributions are included, written by the most distinguished academics, practitioners and representatives of several international tax administrations and both tax and economic institutions.
Explanation Of Proposed Protocol To The Income Tax Treaty Between The United States And The Kingdom Of The Netherlands In Respect Of The Netherlands Antilles
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Author :
language : en
Publisher:
Release Date : 1996
Explanation Of Proposed Protocol To The Income Tax Treaty Between The United States And The Kingdom Of The Netherlands In Respect Of The Netherlands Antilles written by and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1996 with Business & Economics categories.
Access To Treaty Benefits
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Author : Desiree Auer
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-09-21
Access To Treaty Benefits written by Desiree Auer 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 2021-09-21 with Law categories.
A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.
Tax Treaties And Domestic Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2006
Tax Treaties And Domestic 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 2006 with Double taxation categories.
This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.