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 written by Organisation for Economic Co-operation and Development and published by Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications Information Centre. This book was released on 1992 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Four reports of the OECD that have resulted in changes to the Commentary of the Model Tax Convention on Income and on Capital. The studies deal with the computation of the 183-day rule of sub-paragraph 2b) of Article 15 of the Model, the application of tax conventions to "triangular cases", the tax treatment of software payments and the tax treatment of employees' contributions to foreign pension schemes.
Download or read book Issues in International Taxation International Tax Avoidance and Evasion Four Related Studies written by OECD and published by OECD Publishing. This book was released on 1987-04-30 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt: The first report outlines the reasons why international tax avoidance and evasion through the use of tax havens is a concern to the tax authorities of OECD Member countries and examines measures introduced to combat such use. The second report sets out the problems posed for tax administrations by the fact that their resident taxpayers make use of base companies (generally subsidiary companies) in tax havens to shelter there income derived from source countries (which may in some cases be the residence country itself) and in that way to escape tax normally payable to the country of residence. The third report deals with the problems created for tax authorities in source countries by the mechanism of "treaty shopping". The final report deals with taxation and the abuse of bank secrecy.
Download or read book International Tax Avoidance and Evasion written by Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs and published by Organization for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Centre. This book was released on 1987 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: Compilation of four related studies.
Download or read book Models with Impact Or Merely Conventional Examples A Quantitative Exploration of the Relationship Between the UN Model Convention and the Bilateral Treaty Network on the Issue of the Taxation of Services written by M. A. Lemmens and published by . This book was released on 2016 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt: States need revenue to provide for the common basic needs in order for a society to prosper. Taxation is the key source of revenue. As of this importance, taxation remains a policy field in which state sovereignty persists. However, the globalizing world puts pressure on the sovereignty. The international taxation regime, consisting of bilateral treaties, domestic law and model conventions, is evolved to face its challenges. The relationships within this international taxation regime is the topic of this research, more specifically the relationship between model conventions and the bilateral treaty network. A quantitative analysis using the IBFD Tax Treaty Database provides insight in some key trends in the bilateral treaty network with regard to three articles on the taxation of services: the deemed service permanent establishment, the broadened royalty article, and the separate service fee withholding tax article. The result is that there does not seem to be a significant relationship between the UN Model Convention and the bilateral treaties on this highly political topic. Therefore, it seems that one should think twice about promoting model conventions in order to solve problems or faults in this regime that surpass technical and administrative issues.
Download or read book Tax Law Design and Drafting Volume 1 written by Mr.Victor Thuronyi and published by International Monetary Fund. This book was released on 1996-08-23 with total page 534 pages. Available in PDF, EPUB and Kindle. Book excerpt: Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.
Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2019-05-02 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
Download or read book Individuals Income Under Double Taxation Conventions written by Daniel Vitor Bellan and published by Kluwer Law International B.V.. This book was released on 2010-01-01 with total page 466 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.
Download or read book The Improper Use of Tax Treaties With Particular Reference to the Netherlands and the United States written by Stef Weeghel and published by Kluwer Law International B.V.. This book was released on 1998-03-27 with total page 302 pages. Available in PDF, EPUB and Kindle. Book excerpt: "With particular reference to the Netherlands and the United States."--T.p.
Download or read book The Impact of Tax Treaties and EU Law on Group Taxation Regimes written by Bruno da Silva and published by Kluwer Law International B.V.. This book was released on 2016-07-11 with total page 650 pages. Available in PDF, EPUB and Kindle. Book excerpt: Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities – differences arising from the interaction of different tax systems – and obstacles – distortions created by domestic legislation arising from differences between domestic and cross-border situations – both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: – analysis of the different tax group regimes adopted by different countries; – advantages and disadvantages of a variety of models; – application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; – application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; – uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; – interrelations between tax treaties and EU Law in the context of tax groups; and – per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.
Download or read book A Global Analysis of Tax Treaty Disputes written by Eduardo Baistrocchi and published by Cambridge University Press. This book was released on 2017-08-17 with total page 2216 pages. Available in PDF, EPUB and Kindle. Book excerpt: This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
Download or read book Tax Treaties and Controlled Foreign Company Legislation Pushing the Boundaries written by Daniel Sandler and published by Kluwer Law International B.V.. This book was released on 1998-07-29 with total page 326 pages. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.
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 International Tax Planning and Prevention of Abuse written by Luc De Broe and published by IBFD. This book was released on 2008 with total page 1146 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.
Download or read book Klaus Vogel on Double Taxation Conventions written by Ekkehart Reimert and published by Kluwer Law International B.V.. This book was released on 2022-01-18 with total page 3112 pages. Available in PDF, EPUB and Kindle. Book excerpt: Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University
Download or read book Preventing Treaty Abuse written by Daniel Blum and published by Linde Verlag GmbH. This book was released on 2016-09-19 with total page 473 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.
Download or read book IBFD International Tax Glossary written by Julie Rogers-Glabush and published by IBFD. This book was released on 2009 with total page 561 pages. Available in PDF, EPUB and Kindle. Book excerpt: Authoritative resource for defining tax and tax-related terms. With the addition of over 120 completely new definitions and over 100 substantially revised descriptions, this edition contains more than 2,000 tax terms, clearly and concisely defined in English; alphabetical listing of some 400 English terms together with their French, German, Spanish and Dutch equivalents; cross-referenced listing of terms indicating similar, related and contrasting terms; abbreviations and bibliographical references to aid further research; a list of tax-related organizations, with brief descriptions and Internet addresses; accurate descriptions of both traditional and more obscure terms; expanded coverage of terms relating to customs, VAT, capital taxes, transfer pricing and EU tax law terminology; a separate extensive list of tax-related organizations in some 40 countries.
