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 Guide to US UK Private Wealth Tax Planning written by Robert L Williams and published by Bloomsbury Publishing. This book was released on 2015-09-24 with total page 815 pages. Available in PDF, EPUB and Kindle. Book excerpt: This unique book is a concise but complete tax planning manual for those advising high net worth individuals of the UK, US or any other nationality who have UK or US residence, assets or family members. Guide to US/UK Private Wealth Tax Planning covers all the information and legislation you are likely to require when advising clients exposed to both UK and US taxation, providing you with: A quick reference summary of the UK and US rules applicable to your clients; A comprehensive summary of available unilateral and treaty planning techniques to avoid US estate tax or UK inheritance tax for clients who are non-domiciliaries of the UK or US; Optimal income and gains tax planning for foreign trusts with UK or US beneficiaries; Integrated UK and US tax planning solutions for clients exposed to both UK and US tax. Previous edition ISBN: 9781845920272
Download or read book Tax Protocols with the United Kingdom and the Netherlands written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1966 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Supplementary Tax Protocol with the United Kingdom of Great Britain and Northern Ireland written by United States. President (1963-1969 : Johnson) and published by . This book was released on 1966 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax By Design written by Stuart Adam and published by Oxford University Press. This book was released on 2011-09 with total page 552 pages. Available in PDF, EPUB and Kindle. Book excerpt: Based on the findings of a commission chaired by James Mirrlees, this volume presents a coherent picture of tax reform whose aim is to identify the characteristics of a good tax system for any open developed economy, assess the extent to which the UK tax system conforms to these ideals, and recommend how it might be reformed in that direction.
Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Download or read book Tax Treaties with the United Kingdom the Republic of Korea and the Republic of the Philippines written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1977 with total page 508 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Double Taxation and the League of Nations written by Sunita Jogarajan and published by Cambridge University Press. This book was released on 2018-05-10 with total page 356 pages. Available in PDF, EPUB and Kindle. Book excerpt: Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Download or read book Beneficial Ownership in International Tax Law written by Angelika Meindl-Ringler and published by Kluwer Law International B.V.. This book was released on 2016-06-07 with total page 448 pages. Available in PDF, EPUB and Kindle. Book excerpt: In international tax law, the term ‘beneficial ownership’ refers to which parties involved in a cross-border transaction are entitled to tax treaty benefits. However, determining beneficial ownership is a complex and often disputed issue, subject to different meanings in different countries. Archival research on its early use in tax treaties and in the developing OECD Model reveals that its meaning has changed dramatically over the decades, leading to new interpretations significantly affecting current tax practice and scholarship. This book, dedicated to establishing how beneficial ownership should ideally be interpreted, compares the use and interpretation of benefi-cial ownership, both current and historical, in a wide range of national jurisdictions as well as the EU, ultimately shedding a clearer light than has heretofore been available on the meaning of the term. In her very thorough analysis of the application of beneficial ownership, the author touches on such aspects as the following: – historical development of the beneficial ownership requirement as used in tax treaties and in the OECD Model Tax Convention on Income and on Capital; – rules of double taxation conventions; – application of the OECD’s Action Plan on Base Erosion and Profit-Shifting (BEPS); – the problem of so-called ‘white income’; – use of the substance-over-form principle; – attribution-of-income rules; and – the role of agents, nominees, and conduit companies. Specific analysis of the use and interpretation of beneficial ownership in a domestic law and treaty context in numerous jurisdictions – with particular emphasis on the United Kingdom, Australia, the United States, and Germany – is a major feature of the presentation. As a thorough guide to determining whether a person claiming tax treaty benefits is the true owner – and which parties are excluded from treaty benefits and to what extent – this book will be of immeasurable value to lawyers, tax authorities, policymakers, and other professionals working with taxable international transactions of any kind.
Download or read book Self employment Tax written by and published by . This book was released on 1988 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Convention with the United Kingdom T Doc 107 19 and Protocols Amending Tax Conventions with Australia T Doc 107 20 and Mexico T Doc 108 3 written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 2003 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Doing Business 2020 written by World Bank and published by World Bank Publications. This book was released on 2019-11-21 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Seventeen in a series of annual reports comparing business regulation in 190 economies, Doing Business 2020 measures aspects of regulation affecting 10 areas of everyday business activity.
Download or read book Introduction to the Law of Double Taxation Conventions written by Michael Lang and published by Linde Verlag GmbH. This book was released on 2021-04-01 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Download or read book Third Protocol to the 1975 Income Tax Convention with the United Kingdom of Great Britain and Northern Ireland as Amended written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1979 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Convention with the United Kingdom written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 2003 with total page 24 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Estate and Gift Tax Treaty with the United Kingdom of Great Britain and Northern Ireland written by United States. Congress. Senate. Committee on Foreign Relations and published by . This book was released on 1979 with total page 66 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Legislative History of United States Tax Conventions Death gift tax conventions written by and published by . This book was released on 1962 with total page 1476 pages. Available in PDF, EPUB and Kindle. Book excerpt:
