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Author: Sunita Jogarajan
Publisher: Cambridge University Press
ISBN: 1108383742
Category : Law
Languages : en
Pages : 356
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Book Description
Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Author: Sunita Jogarajan
Publisher: Cambridge University Press
ISBN: 1108383742
Category : Law
Languages : en
Pages : 356
Get Book Here
Book Description
Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.
Author: Karl P Sauvant
Publisher: Oxford University Press
ISBN: 0199745188
Category : Law
Languages : en
Pages : 795
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Book Description
Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
Author: Kevin Holmes
Publisher: IBFD
ISBN: 9087220235
Category : Double taxation
Languages : en
Pages : 433
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Book Description
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.
Author: Juan Angel Becerra
Publisher: IBFD
ISBN: 9087220197
Category : Canada
Languages : en
Pages : 299
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Book Description
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Author: Michael Kobetsky
Publisher: Cambridge University Press
ISBN: 1139500228
Category : Law
Languages : en
Pages : 469
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Book Description
The effects of the growth of multinational enterprises and globalization in the past fifty years have been profound, and many multinational enterprises, such as international banks, now operate around the world through branches known as permanent establishments. The business profits article (Article 7) of the OECD model tax treaty attributes a multinational enterprise's business profits to a permanent establishment in a host country for tax purposes. Michael Kobetsky analyses the principles for allocating the profits of multinational enterprises to permanent establishments under this article, explains the shortcomings of the current arm's length principle for attributing business profits to permanent establishments and considers the alternative method of formulary apportionment for allocating business profits.
Author: Karen Gram-Skjoldager
Publisher: Aarhus Universitetsforlag
ISBN: 877184838X
Category : History
Languages : en
Pages : 285
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Book Description
The League of Nations - Perspectives from the Present is an accessible and richly illustrated edited volume displaying a wide variety of cutting-edge research on the many ways the League of Nations shaped its times and continues to shape our contemporary world. A series of bite-size studies, divided into three thematic parts, investigates how the League affected the world around it and the lives of the people who became part of this 'first great experiment' in international organisation. Recent research has reinterpreted the League as a laboratory of global economic, political and humanitarian governance. Expanding on this, the volume aims to show that the League is an 'academic site', where international history - as a discipline - has re-invented itself by integrating new approaches from social, cultural and media history. With an introduction by Director-General Michael Moller of the United Nations Organisation in Geneva, this work is a timely reminder of the fragile, varied and enduring history of multilateralism, on the centenary of the signing of the Treaty of Versailles.
Author: Tsilly Dagan
Publisher: Cambridge University Press
ISBN: 1107112109
Category : Business & Economics
Languages : en
Pages : 263
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Book Description
Explains why perfecting, rather than curbing, interstate competition would make international taxation both more efficient and more just.
Author: Thomas Ecker
Publisher:
ISBN: 9783707320114
Category : Double taxation
Languages : en
Pages : 734
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Book Description
This book provides an historical in-depth analysis for each provision in the OECD MC. It offers a refurbished presentation of the history and internal processes of the international organizations involved in the tax treaty models' development. This historical analysis helps the reader understand the design and content of certain provisions, as well as their role in the system as a whole. As such, the value of an historical analysis goes far beyond mere understanding of the past: it also provides tools for interpretation. By using those tools, one can solve numerous current interpretation issues and gain new insights for future improvements of the OECD MC.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264287957
Category :
Languages : en
Pages : 658
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Book Description
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...
Author: United States. Congress. Joint Committee on Internal Revenue Taxation
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 1532
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Book Description
