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 Issues in International Taxation Issues Related to Article 14 of the OECD Model Tax Convention written by and published by . This book was released on 2000 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Issues in International Taxation The Application of the OECD Model Tax Convention to Partnerships written by OECD and published by OECD Publishing. This book was released on 1999-08-26 with total page 131 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report addresses the issue of the application of tax treaties to cases involving partnerships in detail and focuses on specific factual examples.
Download or read book Issues Related to Article 14 of the OECD Model Tax Convention written by Organització de Cooperació i Desenvolupament Econòmic and published by . This book was released on 2000 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Issues in International Taxation 2002 Reports Related to the OECD Model Tax Convention written by OECD and published by OECD Publishing. This book was released on 2003-05-16 with total page 129 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication includes three recent reports that resulted in changes to the OECD Model Tax Convention. One covers entitlement to treaty benefits, another covers e-commerce, and the third covers issues arising under the permanent establishment article.
Download or read book Model Tax Convention on Income and on Capital 2014 Full Version written by OECD and published by OECD Publishing. This book was released on 2015-10-30 with total page 2289 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the ninth 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 15 July 2014.
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Issues in International Taxation No 07 Issues Related to Article 14 of the OECD Model Tax Convention
Download or read book Issues in International Taxation No 07 Issues Related to Article 14 of the OECD Model Tax Convention 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 Issues in International Taxation Model Tax Convention Four Related Studies written by OECD and published by OECD Publishing. This book was released on 1992-12-23 with total page 97 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication, includes four recent reports of the Committee on Fiscal Affairs that have resulted in changes to the Commentary of the Model Tax Convention on Income and on Capital.
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 2017 Full Version written by OECD and published by OECD Publishing. This book was released on 2019-04-25 with total page 2624 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the tenth 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 as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 582 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.
Download or read book The 2010 OECD Updates written by Dennis Manolito Weber and published by Kluwer Law International B.V.. This book was released on 2011-01-01 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt: Virtually all international taxation provisions ultimately stem from two fundamental sources, both originating at the OECD: The Model Tax Convention (on which more than 3,000 bilateral tax treaties are based), and the Transfer Pricing Guidelines. During 2010, major revisions were made to both. This unique book provides an expert analysis of current, important topics in international taxation and transfer pricing. As such, it is a welcome and valuable resource for tax lawyers and consultants, corporate tax advisers, government officials and others involved in the international tax law market, as well as for academics and researchers in the field.
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 Issues Related to Article 14 of the OECD Model Tax Convention written by OCSE. and published by . This book was released on 2000 with total page 45 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 The Legal Status of the OECD Commentaries written by Sjoerd Douma and published by IBFD. This book was released on 2008 with total page 284 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since the mid-1980s, the legal basis of the practice of tax administrations and courts around the world to conform to the Commentaries when interpreting and applying bilateral tax treaties based on the OECD Model has been the subject of an ongoing academic debate. Recently the debate has received new impetus, and the primary focus is now on the general principles of international law. In particular, opinions differ on the question whether the Commentaries can be a source of legal obligations through the principles of acquiescence and estoppel, both of which are founded on considerations of good faith, and equity and provide specific protection of settled expectations. The reports contained in this book address two questions. The first is whether, under international law, the states parties to a tax treaty are legally bound by the OECD Commentaries when interpreting and applying the provisions of the treaty which are identical to those of the OECD Model. The second question is whether, under the contracting states' internal law, taxpayers and the tax authorities are equally bound to apply the Commentaries if and when the contracting states themselves are so bound under international law. The book brings various legal disciplines - public international law, international tax law, Community law and constitutional law - together in order to resolve the legal status of the Commentaries. Through interdisciplinary debate, the issues have been defined clearly and the exact points at which the opinions differ are identified, thereby resulting in a better understanding of the issues at hand.
Download or read book Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries written by United Nations Publications and published by . This book was released on 2014 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.