Author: Raffaele Russo
Publisher: IBFD
ISBN: 907607884X
Category : Business enterprises
Languages : en
Pages : 488
Book Description
"The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016
The Attribution of Profits to Permanent Establishments
Author: Raffaele Russo
Publisher: IBFD
ISBN: 907607884X
Category : Business enterprises
Languages : en
Pages : 488
Book Description
"The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016
Publisher: IBFD
ISBN: 907607884X
Category : Business enterprises
Languages : en
Pages : 488
Book Description
"The attribution of profits to permanent establishments (PEs) is probably one of the most complex subjects of the international tax arena. The interaction of treaty rules and domestic legislations sometimes leads to unacceptable results such as double taxation or double non-taxation. This book compares the tax treatment of cross-border dealings between different parts of the same enterprise in several countries."--Extracted from publisher website on June 29, 2016
Courts and Tax Treaty Law
Author: Guglielmo Maisto
Publisher: IBFD
ISBN: 9087220138
Category : Courts
Languages : en
Pages : 435
Book Description
A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.
Publisher: IBFD
ISBN: 9087220138
Category : Courts
Languages : en
Pages : 435
Book Description
A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.
Limitation on Benefits Clauses in Double Taxation Conventions
Author: Félix Alberto Vega Borrego
Publisher: Kluwer Law International B.V.
ISBN: 9041161430
Category : Law
Languages : en
Pages : 438
Book Description
Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Publisher: Kluwer Law International B.V.
ISBN: 9041161430
Category : Law
Languages : en
Pages : 438
Book Description
Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Comentarios a la Ley del impuesto sobre la renta de no residentes
Author: Andrés Sánchez López
Publisher: Aranzadi
ISBN: 9788497672085
Category : Law
Languages : es
Pages : 589
Book Description
Publisher: Aranzadi
ISBN: 9788497672085
Category : Law
Languages : es
Pages : 589
Book Description
EC Tax Review
Author:
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 728
Book Description
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 728
Book Description
Comentarios a la Ley del impuesto sobre la renta de no residentes
Author: Angel Baena Aguilar
Publisher: Civitas Book Publisher
ISBN: 9788447012572
Category : Aliens
Languages : es
Pages : 503
Book Description
Publisher: Civitas Book Publisher
ISBN: 9788447012572
Category : Aliens
Languages : es
Pages : 503
Book Description
Bulletin for International Fiscal Documentation
Author: International Bureau of Fiscal Documentation
Publisher:
ISBN:
Category : Finance
Languages : en
Pages : 652
Book Description
Publisher:
ISBN:
Category : Finance
Languages : en
Pages : 652
Book Description
Differences in Tax Treatment Between Local and Foreign Investors and Effects of International Treaties
Author: International Fiscal Association Staff
Publisher: Springer
ISBN:
Category : Business & Economics
Languages : en
Pages : 516
Book Description
Of national reports on the topic by various contributors participating in the 32nd congress of the International Fiscal Association which was held in Sydney, 1978. The report by the general reporter J. van Hoorn is published in full in four languages.
Publisher: Springer
ISBN:
Category : Business & Economics
Languages : en
Pages : 516
Book Description
Of national reports on the topic by various contributors participating in the 32nd congress of the International Fiscal Association which was held in Sydney, 1978. The report by the general reporter J. van Hoorn is published in full in four languages.
Annual Legal Bibliography
Author: Harvard Law School. Library
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 784
Book Description
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 784
Book Description
Glosario Del Banco Mundial
Author: World Bank
Publisher: World Bank Publications
ISBN:
Category : Business & Economics
Languages : en
Pages : 468
Book Description
This edition of the World Bank has been revised and expanded by the Terminology Unit in the Languages Services Division of the World Bank in collaboration with the English, Spanish, and French Translation Sections. The Glossary is intended to assist the Bank's translators and interpreters, other Bank staff using French and Spanish in their work, and free-lance translator's and interpreters employed by the Bank. For this reason, the Glossary contains not only financial and economic terminology and terms relating to the Bank's procedures and practices, but also terms that frequently occur in Bank documents, and others for which the Bank has a preferred equivalent. Although many of these terms, relating to such fields as agriculture, education, energy, housing, law, technology, and transportation, could be found in other sources, they have been assembled here for ease of reference. A list of acronyms occurring frequently in Bank texts (the terms to which they refer being found in the Glossary) and a list of international, regional, and national organizations will be found at the end of the Glossary.
Publisher: World Bank Publications
ISBN:
Category : Business & Economics
Languages : en
Pages : 468
Book Description
This edition of the World Bank has been revised and expanded by the Terminology Unit in the Languages Services Division of the World Bank in collaboration with the English, Spanish, and French Translation Sections. The Glossary is intended to assist the Bank's translators and interpreters, other Bank staff using French and Spanish in their work, and free-lance translator's and interpreters employed by the Bank. For this reason, the Glossary contains not only financial and economic terminology and terms relating to the Bank's procedures and practices, but also terms that frequently occur in Bank documents, and others for which the Bank has a preferred equivalent. Although many of these terms, relating to such fields as agriculture, education, energy, housing, law, technology, and transportation, could be found in other sources, they have been assembled here for ease of reference. A list of acronyms occurring frequently in Bank texts (the terms to which they refer being found in the Glossary) and a list of international, regional, and national organizations will be found at the end of the Glossary.