Download or read book Taxation of Artistes and Sportsmen in International Tax Law written by Walter Loukota and published by . This book was released on 2007 with total page 502 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Download or read book Taxation Of Artistes And Sportsmen In International Tax Law written by Michael Lang and published by . This book was released on 2008-09-01 with total page 504 pages. Available in PDF, EPUB and Kindle. Book excerpt: Some artistes and sportsmen are 'flying birds'. Especially very famous artistes and sportsmen spread their activity - and thus their income-across several countries. Still, normally they do not have a qualified connection - a permanent establishment in the state of performance or a presence fulfilling the criteria of the 183-days rule-to the state of source. Therefore, the OECD introduced a special rule for artistes and sportsmen.Practical experience shows that cross border activities of artistes and sportsmen cause a lot of issues. Issues are caused by the interpretation of the special rule in tax treaties and their interdependence with other treaty provisions. Besides that, artistes and sportsmen are often confronted with discrimination in the state of source. Last but not least, artistic and sportive activities cause specific VAT issues. This volume strives to analyse these issues and to give conclusions based on the interpretation of current international tax law. Furthermore, the authors intend to show how international tax law could be improved where an improvement seems necessary.

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 Taxation of International Performing Artistes written by Dick Molenaar and published by IBFD. This book was released on 2005 with total page 439 pages. Available in PDF, EPUB and Kindle. Book excerpt: The special tax rules for performing artistes lead to obstacles. This book considers the problems regarding, for example, the determination of taxable income and the non-deductibility of expenses and tax credits in the country of residence, and gives clear examples of excessive taxation.

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 International Taxation of Artistes Sportsmen written by Xavier Oberson and published by . This book was released on 2009 with total page 278 pages. Available in PDF, EPUB and Kindle. Book excerpt:

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 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 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 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 A Tax Globalist written by Maarten J. Ellis and published by IBFD. This book was released on 2005 with total page 379 pages. Available in PDF, EPUB and Kindle. Book excerpt: This Festschrift comprises 20 essays on a wide range of issues of International and European tax law, written by friends and colleagues of Maarten J. Ellis in honour of his academic work, and presented on the occasion of his valedictory lecture held in Rotterdam on 17 March 2005.

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 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 Issues in International Taxation Issues Related to Article 14 of the OECD Model Tax Convention written by OECD and published by OECD Publishing. This book was released on 2000-04-01 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book recommends that Article 14 be eliminated from the OECD Model Tax Convention and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence.

Download or read book Individuals Income under Double Taxation Conventions A Brazilian Approach written by Daniel Vitor Bellan and published by Kluwer Law International B.V.. This book was released on 2010-09-03 with total page 464 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax conventions (or tax treaties) provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. Brazil has over two dozen such conventions in force. This number might seem small but the country will inevitably enter into more such treaties given its economic growth, foreign investments and economic globalization in general. Two highly practical aspects form the basis of the book’s analysis: interpretation and qualification under international tax law; and Brazil’s income tax on individuals. The author employs those starting points to tackle such thorny questions as: Is there coherence in the legal regime that is applicable to individuals’ income in double taxation treaties? Is this “system” for individuals consistent? Is it in accordance with Brazilian constitutional principles? Professionals dealing with Brazil’s tax regime will quickly find this work instructive, insightful and thought-provoking.

Download or read book Source Versus Residence written by Michael Lang and published by . This book was released on 2008 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.

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.