Download or read book Access to Treaty Benefits written by Desiree Auer and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Access to Treaty Benefits written by Desiree Auer and published by . This book was released on 2021 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Limitation on Benefits Clauses in Double Taxation Conventions written by Félix Alberto Vega Borrego and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Download or read book U S Tax Guide for Aliens written by and published by . This book was released on 1998 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book United States Tax Treaties written by United States and published by Springer. This book was released on 1991-02-05 with total page 678 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to the major US tax treaties, and offers the opportunity to compare several Model treaties with actual US treaties. In addition the book includes: withholding rate tables for dividends, interest and royalties in over 150 US and foreign income tax treaties; cross-reference tables for treaty provisions; a chronical listing of all present and past US income tax treaties; the 1963 and 1977 OECD, the 1980 UN and the 1981 US Model Treaties in tabular comparative form; major portions of the 1977 OECD Commentary; examples of estate and gift tax treaties (US-Germany) and of exchange of tax information agreements (US-Mexico); the recently signed Multilateral Convention on Mutual Administrative Assistance in Tax Matters, and an article on interpretation in the Vienna Convention on the Law of Treaties.
Download or read book Issues in International Taxation 2002 Reports Related to the OECD Model Tax Convention written by OECD and published by OECD Publishing. This book was released on 2003-05-16 with total page 129 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication includes three recent reports that resulted in changes to the OECD Model Tax Convention. One covers entitlement to treaty benefits, another covers e-commerce, and the third covers issues arising under the permanent establishment article.
Download or read book Model Tax Convention on Income and on Capital Condensed Version 2017 written by OECD and published by OECD Publishing. This book was released on 2017-12-18 with total page 658 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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...
Download or read book Access to Treaty Benefits written by Desiree Auer and published by Linde Verlag GmbH. This book was released on 2021-09-21 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book U S Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Main Provisions and Benefits of the Marrakesh Treaty 2013 written by World Intellectual Property Organization and published by WIPO. This book was released on 2016-05-26 with total page 8 pages. Available in PDF, EPUB and Kindle. Book excerpt: This leaflet explains how the Marrakesh Treaty works and why it is so important.
Download or read book Bilateral Tax Treaties and Protocol written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1998 with total page 72 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Rules of Professional Conduct written by American Bar Association. House of Delegates and published by American Bar Association. This book was released on 2007 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model Rules of Professional Conduct provides an up-to-date resource for information on legal ethics. Federal, state and local courts in all jurisdictions look to the Rules for guidance in solving lawyer malpractice cases, disciplinary actions, disqualification issues, sanctions questions and much more. In this volume, black-letter Rules of Professional Conduct are followed by numbered Comments that explain each Rule's purpose and provide suggestions for its practical application. The Rules will help you identify proper conduct in a variety of given situations, review those instances where discretionary action is possible, and define the nature of the relationship between you and your clients, colleagues and the courts.
Download or read book Canada U S Tax Treaty written by and published by . This book was released on 1981 with total page 52 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Convention with the Netherlands written by Netherlands and published by . This book was released on 1969 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book An Explanatory Guide to the Nagoya Protocol on Access and Benefit sharing written by Thomas Greiber and published by IUCN. This book was released on 2012 with total page 395 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by . This book was released on 2009 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital 2014 Full Version written by OECD and published by OECD Publishing. This book was released on 2015-10-30 with total page 2289 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the ninth 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 on Income and on Capital as it read on 15 July 2014.
