Download or read book Model Tax Convention on Income and on Capital Condensed Version September 1992 written by OECD and published by OECD Publishing. This book was released on 1992-10-19 with total page 243 pages. Available in PDF, EPUB and Kindle. Book excerpt: Condensed version of the loose-leaf publication "Model tax convention on income and capital", containing the full text of the September 1992 Model Tax Convention, but omitting the historical notes and annexes, which include a detailed list of tax conventions between OECD member countries and the text of the Recommendation of 23 July 1992 from the OECD Council.
Download or read book Model Tax Convention on Income and on Capital written by and published by OECD. This book was released on 1993 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Condensed version of the loose-leaf publication "Model tax convention on income and capital", containing the full text of the September 1992 Model Tax Convention, but omitting the historical notes and annexes, which include a detailed list of tax conventions between OECD member countries and the text of the Recommendation of 23 July 1992 from the OECD Council.
Download or read book Model Tax Convention on Income and on Capital written by and published by . This book was released on 1993 with total page 244 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital 2010 Full Version written by OECD and published by OECD Publishing. This book was released on 2012-08-06 with total page 2134 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the eighth 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 22 July 2010.
Download or read book Model Tax Convention on Income and on Capital written by and published by . This book was released on 2005 with total page 380 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital September 1992 written by and published by . This book was released on 1993 with total page 244 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by . This book was released on 1992 with total page 610 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by . This book was released on with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital written by and published by . This book was released on 2012 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 Model Tax Convention on Income and on Capital Model Tax Convention on Income and on Capital Condensed Version July 2005 written by and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital Updated as of 1st September 1995 written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by . This book was released on 1995 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Full text of the 1992 Model Convention on Income and Capital updated as of 1st September 1995 with Commentaries and historical notes.
Download or read book Model Tax Convention on Income and on Capital Introduction model convention commentary written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by . This book was released on 2000 with total page 664 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital written by and published by . This book was released on 2003 with total page 666 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Model Tax Convention on Income and on Capital written by and published by . This book was released on 2004 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book United States Model Income Tax Convention of September 20 1996 written by U. S. Treasury U.S. Treasury Department and published by CreateSpace. This book was released on 2015-01-02 with total page 132 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Model is drawn from a number of sources. Instrumental in its development was the U.S. Treasury Department's draft Model Income Tax Convention, published on June 16, 1981 ("the 1981 Model") and withdrawn as an official U.S. Model on July 17, 1992, the Model Double Taxation Convention on Income and Capital, and its Commentaries, published by the OECD, as updated in 1995 ("the OECD Model"), existing U.S. income tax treaties, recent U.S. negotiating experience, current U.S. tax laws and policies and comments received from tax practitioners and other interested parties.
Download or read book Applying the Arm s Length Principle to Intra group Financial Transactions written by Robert Danon and published by Kluwer Law International B.V.. This book was released on 2023-08-29 with total page 1053 pages. Available in PDF, EPUB and Kindle. Book excerpt: It is well known that intercompany financing arrangements have become increasingly subject to scrutiny in contexts of applying transfer pricing and anti-tax avoidance-related rules. With contributions by more than 50 leading global transfer pricing and international tax experts from law firms, multinational enterprises, academia, and tax administrations, this book provides unparalleled insights into the application of the Arm’s Length Principle to different types of financial transactions, application of anti-avoidance rules to various intra-group financial arrangements as well as the business value creation process and the dispute management landscape that underlie intra-group financial transactions. With in-depth analysis of the legislation and market developments that fuel the diverse range of financing options available to market participants – and loaded with practical examples and case studies that cover the legal and economic considerations that arise when analysing intra-group finance – the contributors examine such topics and issues as the following: national anti-abuse rules applicable to financial transactions; tax treaty issues; role of credit ratings and impact of implicit support; loans, cash pooling, financial guarantees; transfer pricing aspects of performance guarantees; ‘mezzanine’ financing; considerations for crypto financing; impact of crises situations such as COVID-19; how treasury operations can be structured in a group and the decision-making process involved; how hedges offset or mitigate risks; how to apply the arm’s length principle to factoring and captive insurance transactions; comparability analysis for various transactions; special considerations for transactions carried out by a permanent establishment; EU state aid and its interaction with transfer pricing rules; dispute prevention and resolution tools under the OECD, UN, and EU frameworks; and developing countries’ perspectives, focusing on Brazil, India, and South Africa. Given the challenges facing taxpayers and tax authorities alike, this book will prove an immeasurably valuable reference guide to support tax practitioners, tax administrations, and tax scholars in developing standards and policies in dealing with intra-group financing issues.
