Download or read book Taxation of Services in Treaties Between Developed and Developing Countries written by Fernando Souza de Man and published by . This book was released on 2017 with total page 370 pages. Available in PDF, EPUB and Kindle. Book excerpt: The ease with which services are provided cross-border has increased considerably through the years, but this has not been reflected in the model conventions. Although this may not be an important issue when the flow of services between states is similar, it can have a huge impact on the collecting rights of states into which these services are mainly imported, such as developing countries. Nonetheless, developing countries? claims for more source taxation of services have been consistently neglected in model conventions.00With the intent of analysing whether the claims of developing countries are valid, as well as examining how the current system was structured, the author studies the legal and economic theories that support source and residence taxation and the historical documents concerning model conventions drafted by the League of Nations, the OECD and the United Nations. Furthermore, to better grasp the perspective of developing countries, the author analyses the situations of Brazil and India regarding the taxation of services in their domestic legislation and in their tax treaties, comparing the provisions of the latter with the current provisions in model tax conventions.
Download or read book Taxation of Cross border Provision of Services in Double Tax Conventions Between Developed and Developing Countries a Proposal for New Guidelines written by and published by . This book was released on 2013 with total page 331 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country written by Kiyoshi Nakayama and published by International Monetary Fund. This book was released on 2021-05-04 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: A well-designed regional tax treaty to which developing countries are signatories will include provisions securing minimum withholding taxes on investment income and technical service fees, a taxing right in respect of capital gains from indirect offshore transfers, and guarding against-treaty shopping. A tax treaty policy framework—national or regional—that specifies the main policy outcomes to be achieved before negotiations commence would enable developing countries with more limited expertise and lower capacity for tax treaty negotiations to avoid concluding problematic tax treaties. This note provides guidance for members of regional economic communities in the developing world on what should and should not be included in a regional tax treaty and how to design on a common tax treaty policy framework for use in negotiations of bilateral tax treaties with nonmembers.
Download or read book United Nations Model Convention for Tax Treaties Between Developed and Developing Countries written by Stanley S. Surrey and published by . This book was released on 1980 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 1967, the United Nations Group of Experts on Tax Treaties Between Developed and Developing Countries was established to facilitate the conclusion of tax treaties between developing and developes countries. This task was to be accomplished through the formation of guidelines for these treaties and recommendations for their implementation. This monograph describes the the work of this UN Group.
Download or read book United Nations Model Double Taxation Convention Between Developed and Developing Countries written by United Nations. Department of International Economic and Social Affairs and published by . This book was released on 1980 with total page 280 pages. Available in PDF, EPUB and Kindle. Book excerpt: Text of and commentaries on a model convention prepared under the auspices of the United Nations Ad Hoc Group of Experts on Tax Treaties between Developed and Developing Countries. The model consists of articles based on guidelines formulated by the Group at its various meetings and their commentaries expressed at those meetings together with commentaries, where appropriate, drawn from the OECD's 1977 Model Tax Convention.
Download or read book Guidelines for Tax Treaties Between Developed and Developing Countries written by United Nations. Department of Economic and Social Affairs and published by New York : United Nations. This book was released on 1974 with total page 80 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication contains guidelines consolidated from the previous reports prepared by the Group of Experts on Tax Treaties between Developed and Developing Countries, and it is designed as a handbook to assist the negotiation and to facilitate the conclusion of tax treaties.
Download or read book Taxes Covered written by Patricia Brandstetter and published by IBFD. This book was released on 2011 with total page 281 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ('Taxes covered') of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpetive issues and uncertainties in practical treaty application. This book not only provides in-depth analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of today's tax treaties. The source documents used have rarely found their way into publications before: historical OEEC and OECD Reports and Minutes, originally largely classified as 'restricted' and thus inaccessible to the public for decades, provide an insight into the drafting process of Art. 2 and the discussions of Delegates from various nations on practical implications for treaty application. The book offers a unique perspective on this core treaty provision and aims to provide guidance for determing the 'taxes covered' in any tax treaty"--Page 4 of cover.
Download or read book Tax Treaties Between Developed and Developing Countries written by United Nations. Department of Economic and Social Affairs and published by New York : United Nations. This book was released on 1976 with total page 180 pages. Available in PDF, EPUB and Kindle. Book excerpt: Part one : report of the Ad Hoc Group of Experts on tax treaties between developed and developing countries on its sixth meeting. Part two : issues relating to tax treaties between developed and developing countries : report of the Secretary-General to the Ad Hoc Group of Experts.
Download or read book Double Tax Treaties Between Developing and Developed Countries written by Medury Bhaskara Rao and published by . This book was released on 1983 with total page 244 pages. Available in PDF, EPUB and Kindle. Book excerpt: On economic cooperation and taxation of investment income by non-residents.
Download or read book Cross Border Transactions Between Related Companies A Summary of Tax Rules written by Ernst & Whinney and published by Springer. This book was released on 1985 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt: Comparative study providing an outline of transfer pricing rules and related issues in some countries (Australia, Belgium, Brazil, Canada, Denmark, Finland, France, German Federal Republic, Hong Kong, Ireland, Italy, Japan, Mexico, the Netherlands, New Zealand, Norway, Saudi Arabia, Singapore, SOuth Africa, SPain, Sweden, Switzerland, United Kingdom, U.S.A., Venezuela.
Download or read book Tax Treaties Between Developed and Developing Countries written by UN Group of Experts on Tax Treaties Between Developed and Developing Countries and published by New York : United Nations. This book was released on 1978 with total page 76 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Treaties Between Developed and Developing Countries written by United Nations. Department of Economic and Social Affairs and published by . This book was released on 1973 with total page 220 pages. Available in PDF, EPUB and Kindle. Book excerpt: Part one : report of the Ad Hoc Group of Experts on tax treaties between developed and developing countries on its fourth meeting. Part two : issues relating to tax treaties between developed and developing countries : report of the Secretary-General to the Ad Hoc Group of Experts.
Download or read book United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries written by Alexander Trepelkov and published by . This book was released on 2013 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The UN Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries was developed as part of a project implemented jointly by FfDO and the International Tax Compact. Its ten chapters were drafted by renowned international tax experts on the basis of the inputs provided by officials from national tax authorities in 35 developing countries, representing all regions of the world. Through a novel demand-driven approach, it provides practical guidance to developing countries to effectively implement double tax treaties, especially those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries, having regard to the specific needs and interests of these countries."--Publisher website.
Download or read book Assessing the Effectiveness of Double Taxation Treaties in Harmonizing the Rules Relating to the Jurisdiction to Tax Cross Border Income and Promoting an Equitable International Tax Regime written by Etigwe Uwa and published by . This book was released on 2020 with total page 54 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines whether some certainty and clarity has been achieved with regard to the contentious issue of the jurisdiction to tax by means of the entry into double taxation agreements (DTAs or DTTs). It would also examine whether the existence of double taxation treaties results in the inequitable re-distribution of tax revenues from developing countries to developed countries and whether DTAs have provided a leeway for complex tax avoidance schemes which result in the more harmful malaise of double non taxation. The application of Single Tax Principle as a means of achieving a more equitable and efficient international tax regime would be examined. Simply put, this paper would consider whether Double Tax Treaties have provided clarity, harmony and uniformity with regard to the jurisdiction to tax and whether the international tax regime built on an extensive web of bilateral DTAs is just and equitable especially viewed from the lenses of developing countries and the single tax principle. It is posited below that whilst some measure of certainty has been introduced by DTAs with regard to the overlapping taxing rights of states, the divergence in the application and interpretation of its terms by tax authorities and courts in different jurisdictions still leaves a lot of uncertainty and grey areas with regard to the jurisdiction to tax. It is posited further that the current international tax regime woven into a complex web of DTAs is not just and equitable and does not wholly comply with the single tax principle. Initiatives towards a more equitable, efficient and just tax regime including the Base Erosion and Profit Shifting Project of the OECD would be considered and recommendations for reform made at the end of the paper.
Download or read book International Taxation of Income from Services under Double Taxation Conventions written by Marta Castelon and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 544 pages. Available in PDF, EPUB and Kindle. Book excerpt: The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.
Download or read book Tax Treaties Between Developed and Developing Countries written by and published by . This book was released on 1980 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt:
