Download or read book Australian Tax Treaties 2015 written by Australia and published by . This book was released on 2015-05-10 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Business is becoming more globalised and the number of Australia's tax treaties, information-sharing treaties and other agreements has grown rapidly. Australian Tax Treaties provides the text of all international tax agreements entered into by Australia as at 1 January 2015 in one convenient volume.A perfect accompaniment to the Australian Income Tax Legislation 2015 - 3 Volume Set, it reproduces all of Australia's current tax treaties and Tax Information Exchange Agreements (TIEAs) in alphabetical order, as well as the text of the International Tax Agreements Act. Useful tables are also included to provide relevant dates of effect for each treaty/agreement, references to the Australian Treaty Series and enacting legislation, and a summary of the maximum withholding tax rates applicable under Australia's tax treaties. A new feature of this edition is the inclusion of Australia's new FATCA agreement with the US, affecting Australian banks and financial institutions, which came into force on 30 June 2014.This title is a must-have for anyone advising businesses with cross-border transactions - both Australian businesses that export or import goods or services and overseas-based businesses with Australian operations. Use this book to find the rules for how business and individuals are taxed in Australia and in foreign countries. For example, find out if an individual who works in a foreign country pays tax in that country or in their home country. Oxford University Press Australia & New Zealand is the non-exclusive distributor of this title.
Download or read book The 2015 Australia Germany Tax Treaty BEPS and the Multilateral Instrument written by C.J. Taylor and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article examines the influence of the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) project, prior Australian tax treaty practice, the OECD Model and German tax treaty practice on the 2015 Australia-Germany Tax Treaty (the 2015 Treaty). Reference is made in this article to the Explanatory Memorandum to International Tax Agreements Amendment Bill 2016 in ascertaining the influence of the BEPS recommendations, German tax treaty practice and prior Australian treaty practice on the treaty. Provisions in the 2015 Treaty were compared with recommendations and discussions in the various reports issued by the OECD as part of the BEPS project to determine the extent to which the treaty provisions reflected the BEPS recommendations. To determine whether particular provisions showed the influence of German tax treaty practice, they were compared with the German Model Tax Treaty as published by the German Ministry of Finance. To determine whether particular provisions were consistent with past idiosyncratic features of Australian tax treaty practice, they were compared with provisions in prior Australian tax treaties, with archival records of Australian tax treaty negotiations and with the results of prior investigations of Australian tax treaty practice. The article argues that in future Australia should make further adjustments to its tax treaty practice in a post-BEPS and Multilateral Instrument environment.
Download or read book Australia written by U. S. Department U.S. Department of the Treasury and published by CreateSpace. This book was released on 2014-11-07 with total page 42 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is a technical explanation of the Protocol between the United States and Australia, signed on September 27, 2001, (the "Protocol") amending the Convention between the United States of America and Australia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed on August 6, 1982 (the "Convention"). Negotiations took into account the U.S. Treasury Department's current tax treaty policy, the Treasury Department's Model Income Tax Convention (the "U.S. Model"), published on September 20, 1996, and the Australian Model Tax Convention. Negotiations also took into account the Model Tax Convention on Income and on Capital, published by the Organization for Economic Cooperation and Development, as updated in April 2000 (the "OECD Model"), and recent tax treaties concluded by both countries. The Technical Explanation is an official guide to the Protocol. It reflects the policies behind particular Protocol provisions, as well as understandings reached with respect to the application and interpretation of the Protocol. References in the Technical Explanation to "he" or "his" should be read to mean "he or she" or "his or her."
Download or read book AUSTRALIAN TAX TREATIES 2023 written by and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The New Australia Germany Income and Capital Tax Treaty 2015 a Tax Treaty for the Era of the OECD G20 BEPS Initiative written by M. Markham and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The new Australia-Germany Income and Capital Tax Treaty (2015) responds to the OECD recommendations in the Final Reports of the Base Erosion and Profit Shifting (BEPS) initiative. It is one of the first tax treaties concluded following the OECD/G20 BEPS initiative and the first to incorporate the final OECD recommendations.
Download or read book Australian Tax Treaties 2018 written by Australia and published by . This book was released on 2018 with total page 1152 pages. Available in PDF, EPUB and Kindle. Book excerpt: "A perfect accompaniment to the Australian Income Tax Legislation 2018 - 3 Volume Set, this title provides the text of all international tax agreements entered into by Australia as at 1 January 2018. For ease of reference, this book reproduces all of Australia's current tax treaties and Tax Information Exchange Agreements (TIEAs) in alphabetical order by country, as well as the International Tax Agreements Act and Australia's FATCA agreement with the US. It also includes useful tables that provide relevant dates of effect for each treaty/agreement and references to the Australian Treaty Series and enacting legislation, as well as a table that summarises the maximum withholding tax rates applicable under each of the tax treaties."--Wolters Kluwer CCH website.
Download or read book Australian Tax Treaties written by and published by . This book was released on 2020 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Australian Tax Treaties provides the text of all international tax agreements entered into by Australia. Those agreements are no longer contained in schedules to the International Tax Agreements Act.
Download or read book Australian Tax Treaties written by and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: ”A perfect accompaniment to the Australian Income Tax Legislation 2023- 3 Volume Print Set, this book provides the text of all international tax agreements entered into by Australia as at 1 January 2023. For ease of reference, this book reproduces all of Australia's current tax treaties and Tax Information Exchange Agreements (TIEAs) in alphabetical order by country, the International Tax Agreements Act 1953, as well as Australia's FATCA agreement with the US and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the Multilateral Convention). Selected tax treaties include notations to reflect modifications made by the Multilateral Convention, obtained from the synthesised text of the relevant treaties published by the Australian Taxation Office. This book also includes useful tables that provide relevant dates of effect for each treaty/agreement and references to the Australian Treaty Series and enacting legislation, as well as a table that summarises the maximum withholding tax rates applicable under each of the tax treaties. A must-have for professionals advising taxpayers engaged in cross-border transactions or with foreign sourced income, this book assists in locating the rules for the allocation of taxing rights between countries.”--Wolters Kluwer CCH website.
Download or read book A Brave New Post BEPS World New Double Tax Treaty Between Germany and Australia Implements BEPS Measures written by L. Maurer and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The article analyses the key features of the new tax treaty between Germany and Australia, which entered into force on 7 December 2016. The treaty was signed on 12 November 2015 and replaces the existing treaty between both countries signed in 1972. The treaty is one of the first double tax treaties to be concluded globally since the finalization of the OECD BEPS Action Plan and thus represents a significant landmark on the global tax landscape that may indicate the trajectory of post-BEPS double tax treaties. The treaty applies from 1 January 2017 in Germany and from 1 January 2017 (withholding tax), 1 April 2017 (fringe benefits tax) and 1 July 2017 (other Australian taxes) respectively in Australia.
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Download or read book Tax Treaty Case Law around the Globe 2019 written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2020-07-22 with total page 309 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 2018. 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, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Download or read book OECD Arbitration in Tax Treaty Law written by Alicja Majdanska and published by Linde Verlag GmbH. This book was released on 2018-09-14 with total page 740 pages. Available in PDF, EPUB and Kindle. Book excerpt: Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes.
Download or read book Tax Treaty Case Law around the Globe 2020 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2021-08-04 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that were decided around the world in 2019. 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, “Tax Treaty Case Law around the Globe 2020” is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics
Download or read book Action Plan on Base Erosion and Profit Shifting written by OECD and published by OECD Publishing. This book was released on 2013-07-19 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.
Download or read book Tax Treaty Case Law around the Globe 2016 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2017-01-05 with total page 423 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Global Overview of International Tax Disputes on DTC This book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases which were decided in 2015 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2016 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics.
Download or read book Hybrid Entities in Tax Treaty Law written by Sriram Govind and published by Linde Verlag GmbH. This book was released on 2020-09-03 with total page 696 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.
