Treaty Overriding
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Tax Treaty Override
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Author : Carla De Pietro
language : en
Publisher: Kluwer Law International
Release Date : 2014
Tax Treaty Override written by Carla De Pietro and has been published by Kluwer Law International this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014 with Conflict of laws categories.
The term è^-treaty overrideè^-- has acquired a specific connotation for tax treaty purposes, which requires an in-depth analysis. There is a tendency for domestic legislation to be passed (or court cases decided) which may override provisions of tax treaties. Despite the many conflicts and uncertainties about what tax treaty override exactly is and the exact point in time when tax treaty override occurs, its implications have not until now been analysed in a systematic manner.
Treaty Overriding
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Author : Martin Schäfer
language : de
Publisher: Mohr Siebeck
Release Date : 2020-02-03
Treaty Overriding written by Martin Schäfer and has been published by Mohr Siebeck this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020-02-03 with Law categories.
Der vorsätzliche Bruch völkerrechtlicher Verträge durch den Gesetzgeber wirft eine Vielzahl verfassungsrechtlicher Fragen auf. Martin Schäfer untersucht, inwieweit unter anderem die vielzitierte Völkerrechtsfreundlichkeit des Grundgesetzes und das Gewaltenteilungsprinzip dieser Praxis entgegenstehen.
Deutsches Tax Treaty Overriding
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Author : Ronald Gebhardt
language : de
Publisher: Springer-Verlag
Release Date : 2012-12-13
Deutsches Tax Treaty Overriding written by Ronald Gebhardt and has been published by Springer-Verlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-12-13 with Business & Economics categories.
Grenzüberschreitend tätige Wirtschaftssubjekte sehen sich in vielerlei Fällen einer Doppelbesteuerung ausgesetzt. Zur Vermeidung dieses wettbewerbsverzerrenden Zustandes existieren bilaterale Verträge in Form von Doppelbesteuerungsabkommen (DBA). Als Gegenstück existiert in Deutschland seit mehr als 20 Jahren das Instrumentarium des so genannten Treaty Overriding, welches den Rechtszustand der einseitigen Abweichung von einem DBA beschreibt. Ronald Gebhardt beleuchtet das überaus facettenreiche Phänomen aus völker-, verfassungs- und unionsrechtlicher Perspektive, beleuchtet erstmals auch die ökonomischen Implikationen und bietet eine vollumfängliche Gesamtsystematisierung.
Tax Treaty Case Law Around The Globe 2017
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2018-02-20
Tax Treaty Case Law Around The Globe 2017 written by Michael Lang 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 2018-02-20 with Law categories.
A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the forty-one most important tax treaty cases which were decided around the world in 2016. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, the proposed book is a valuable reference tool for all tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics who are active in tax treaty case law.
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.
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.
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.
Treaties In Parliaments And Courts
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Author : Felix Lange
language : en
Publisher: Edward Elgar Publishing
Release Date : 2024-03-14
Treaties In Parliaments And Courts written by Felix Lange 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 2024-03-14 with Political Science categories.
Highlighting the close relationship between foreign relations law and international law, this impressive book places parliament and domestic courtsÕ engagement with treaties at the heart of its inquiry. It presents a timely assessment of the impact that different rules of constitutional law have on parliamentary and judicial approaches to treaties in four different states (Germany, India, South Africa and the US), thereby incorporating valuable comparative dimensions.
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.
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, ...
