Download or read book Domestic Attribution of Income and Taxation of International Entertainers and Sportspersons written by Erich Schaffer and published by . This book was released on 2017 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt: The attribution of income to a certain taxpayer is an issue that virtually every tax jurisdiction has to deal with, but there is no uniform international consensus on how taxable profits are to be allocated to taxpayers, and the details on how to allocate profits are regulated individually by each state. However, consistent principles for the attribution of income are particularly of interest with regard to the application of article 17 of the OECD Model Convention, the relevant allocation rule for the income of entertainers and sportspersons. This provision applies not only to income that is directly attributable to a given entertainer or sportsperson but also to income from an entertaining or sporting activity that accrues to another person. This book provides detailed insight into the treatment of entertainers and sportspersons in international tax law, with the relevance of the domestic attribution of income for the application of tax treaties with regard to entertainers and sportspersons as the focus of attention. Given this focus, the book also establishes how allocation conflicts - i.e. situations where different states attribute the same item of income to different taxpayers according to their domestic attribution principles - can be resolved in a methodically consistent and comprehensive manner with regard to international entertainers and sportspersons.

Download or read book The Taxation of International Entertainers and Athletes All the World s a Stage written by Daniel Sandler and published by Springer. This book was released on 1995-09-21 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Taxation of International Entertainers and Athletes: All the World's a Stage provides a comprehensive and detailed analysis of the taxation of non-resident entertainers and athletes in seven countries: Australia, Canada, France, Germany, Japan, the United Kingdom and the United States. The book deals with the many sources of income which such individuals can derive, including income from live performances, television appearances, commercials, product endorsements, royalties for record sales or `needle time', and merchandising of concert paraphernalia. The primary focus of the book is income tax, although VAT regimes are also considered. In addition, the book provides in-depth analysis of Article 17 (Artists and Sportsmen) of the OECD Model Tax Treaty, particularly regarding the extensive additions to the Commentary to that Article made in 1992 based on the OECD's 1987 report on the taxation of entertainers and athletes. The book contains a table summarising the tax treaty provisions applicable to personal services income derived by entertainers and athletes in the seven countries reviewed. Two examples (one dealing with a touring pop group and the other with a professional tennis player) are used to illustrate, compare and contrast the manner in which income earned by non-resident entertainers and athletes is treated under domestic income tax and VAT regimes (where applicable) in these countries. Finally, conclusions are drawn, at the domestic and international levels, regarding policy and practical considerations in the effective and efficient taxation of such individuals.

Download or read book Taxation of Entertainers and Sportspersons Performing Abroad written by Guglielmo Maisto and published by . This book was released on 2016 with total page 600 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxation of Entertainers and Sportspersons Performing Abroad', comprising the proceedings and working documents of an annual seminar held in Milan in November 2015, is a detailed and comprehensive study on the taxation of highly mobile individuals engaged in the artistic and sports sectors. It begins with a comparative analysis of the domestic tax regime of such individuals and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union. 0The book then moves to selected tax treaty issues. In particular, it analyses: (i) the history of article 17 of the OECD Model Tax Convention; (ii) recent developments concerning that article, particularly the 2014 amendments to the Commentary on Article 17 of the OECD Model Convention; (iii) tax treaty issues related to qualification, allocation and apportionment of income derived by entertainers and sportspersons; and (iv) the taxation of income from image rights, sponsorship and advertising.

Download or read book Taxation of Entertainers Athletes and Artists written by Lionel S. Sobel and published by American Bar Association. This book was released on 2015 with total page 390 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the specialized issues affecting the income taxation of entertainers, athletes, and artists. It considers both domestic and international taxation. It includes numerous examples, calculations, charts and graphs.

Download or read book Taxation of Non Resident Entertainers written by International Fiscal Association Staff and published by Springer. This book was released on 1996-10-23 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Proceedings of a seminar held in Cannes, France, in 1995 during the 49th congress of the International Fiscal Association. Survey of the international tax treatment of non-resident entertainers and athletes under both domestic law and tax treaties. Introduction summarizes the main issues including source and characterization of income, loan out companies and definition of entertainers and athletes.

Download or read book Issues in International Taxation Thin Capitalisation Taxation of Entertainers Artistes and Sportsmen written by OECD and published by OECD Publishing. This book was released on 1987-05-02 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication brings together two reports prepared by the Committee on Fiscal Affairs; "Thin Capitalisation" and "The Taxation of Income Derived from Entertainment, Artistic and Sporting Activities",

Download or read book Tax and Financial Planning for Sportsmen and Entertainers written by Richard Baldwin and published by Lexis Law Publishing (Va). This book was released on 1987 with total page 198 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Research Handbook on International Taxation written by Yariv Brauner and published by Edward Elgar Publishing. This book was released on 2020-12-25 with total page 416 pages. Available in PDF, EPUB and Kindle. Book excerpt: Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.

Download or read book Taxation of Foreign Entertainers and Sportsmen written by Beate Erwin and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: " ... analyzes the U.S. income tax laws applicable to nonresident alien artists, performing artists, entertainers, and athletes (together referred to as "performers") who derive income from U.S. sources, either relating to performances in the United States or rights extending to intellectual property rights in the United States"--Portfolio description (page iii).

Download or read book The International Guide to the Taxation of Sportsmen and Sportswomen written by Rijkele Betten and published by . This book was released on 2002 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book International Taxation Law in Sports Events written by Alara Efsun Yazıcıoğlu and published by Routledge. This book was released on 2020-07-28 with total page 259 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is the first academic contribution that deals with international taxation of income sources from sports events. Using an interdisciplinary approach, with in-depth analysis of both sports law and international tax law, it is notably the first academic work to conduct a thorough analysis in the fields of international taxation of eSports, sports betting as well as illegal/unlawful income sources that may be obtained in relation to a sporting event, such as kickback payments. After describing the general methodologies of income tax and VAT from an international standpoint, defining key terms such as ‘eSports’ and ‘bidding procedure’, the book examines in detail the taxation of the services that are rendered and the goods that are sold, thereby the income obtained, in relation to an international sports event from both income tax and VAT perspectives. Also analysed are government funding in the sports sector, along with its taxation modalities, as well as specific tax exemption regulations enacted for the purposes of mega sporting events. Highlighting the absence of an acceptable level of certainty in the field of taxation of international sports events, the work makes pertinent suggestions as to the future of international sporting event taxation law. With international appeal, this comprehensive book constitutes essential reading for tax and sports law scholars.

Download or read book Thin Capitalisation Taxation of Entertainers Artistes and Sportsmen written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications and Information Centre. This book was released on 1987 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt: In the first report the various forms that hidden capitalisation can take are examined, the implications for tax yields and the ways in which countries can use double taxation treaties to deal with these situations. In the second report the problems that arise for tax authorities from entertainment and sporting activities are described and the measures they have taken to counteract non-compliance in this area.

Download or read book Taxation of the Entertainment Industry written by Schuyler M. Moore and published by CCH. This book was released on 2008 with total page 444 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxation of the Entertainment Industry (Ninth Edition) is an insightful treatise that helps practitioners spot unique issues before they become problems, interpret rules and regulations correctly, make business decisions that lower taxes, and ensure compliance with the law. This valuable reference by expert practitioner and author, Schuyler Moore, provides in-depth treatment of the taxation of film and television industries, including music and sports. It provides insights on proven strategies and techniques for achieving solid bottom-line results for those practitioners with clients within the entertainment industry.

Download or read book Taxation of International Sportsmen written by Karolina Tetłak and published by . This book was released on 2014 with total page 350 pages. Available in PDF, EPUB and Kindle. Book excerpt: "Taxation of International Sportsmen provides a detailed analysis of the tax breaks offered to non-resident players to supplement or even replace article 17 of the OECD Model and national law based on it. The book also provides an insight into why such alternative measures are adopted and whether article 17 could be changed to meet the requirements of today's championships."--Extracted from publisher website on March 25, 2014.

Download or read book Klaus Vogel on Double Taxation Conventions written by Ekkehart Reimert and published by Kluwer Law International B.V.. This book was released on 2022-01-18 with total page 3112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University

Download or read book Tax Treaty Case Law around the Globe 2018 written by Eric Kemmeren and published by Linde Verlag GmbH. This book was released on 2019-06-13 with total page 478 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 35 most important tax treaty cases which were decided around the world in 2017. 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 2018 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 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.