Issues in International Taxation Model Tax Convention: Four Related Studies PDF Download
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Author: OECD
Publisher: OECD Publishing
ISBN: 9264537600
Category :
Languages : en
Pages : 97
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Book Description
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.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264537600
Category :
Languages : en
Pages : 97
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Book Description
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.
Author: Organisation for Economic Co-operation and Development
Publisher: Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications Information Centre
ISBN:
Category : Business & Economics
Languages : en
Pages : 112
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Book Description
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.
Author: OECD
Publisher: OECD Publishing
ISBN: 926460507X
Category :
Languages : en
Pages : 108
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Book Description
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.
Author: Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Publisher: Organization for Economic Co-operation and Development ; [Washington, D.C. : OECD Publications and Information Centre
ISBN:
Category : Business & Economics
Languages : en
Pages : 124
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Book Description
Compilation of four related studies.
Author: Dhruv Sanghavi
Publisher: Bloomsbury Publishing
ISBN: 9390176867
Category : Business & Economics
Languages : en
Pages : 530
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Book Description
Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom
Author: Organisation for Economic Co-operation and Development
Publisher: Organisation for Economic Co-operation and Development ; Washington, D.C. : OECD Publications and Information Centre
ISBN:
Category : Law
Languages : en
Pages : 60
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Book Description
This publication examines the circumstances under which income is to be attributed to a permanent establishment for purposes of an income tax treaty, particularly where goods, services, or intangibles are transferrred between the permanent establishment and the home office or another permanent establishment in a third country.
Author: M. A. Lemmens
Publisher:
ISBN:
Category :
Languages : en
Pages : 46
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Book Description
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.
Author: Sergio André Rocha
Publisher:
ISBN: 9789403518367
Category :
Languages : en
Pages : 0
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Book Description
Because the normative concepts referred to in tax treaties are susceptible to contextual variation, the rules embedded in such treaties cannot be applied without interpretation. In this incomparable book, an internationally known tax law practitioner and scholar draws on decades of knowledge-gathering to present a deeply evolved general theory of tax treaty interpretation, thoroughly discussing the starting points and elements of interpretation that should be considered by all stakeholders in the field of international taxation. In the course of his rigorous commentary, the author invokes the established canons that apply to the interpretation of tax treaties, including the Vienna Convention on the Law of Treaties and the OECD and UN Model Conventions. He presents a detailed investigation of the implications for tax treaty interpretation of such topics and issues as the following: essential concepts such as "context" and "qualification"; evolution of international taxation from bilateralism to multilateralism; specific interpretation issues raised by bilateral tax treaties; economic crises as drivers for changes in international taxation rules; the OECD/G-20 BEPS project; digitalization of the economy; pandemic, war, and deglobalization; interpretation of international treaties versus interpretation of domestic laws; and interpretation of double tax conventions in countries that are not OECD members. In the absence of a declaration of international tax principles, this book's in-depth analysis of the theory of interpretation of international tax treaties--given the risks of interpreting treaties with different jurisdictions and different languages--will ensure an appropriate understanding of the current context of international taxation, providing practitioners and policymakers with a fully informed background that will guide the interpretation of any international tax treaty.
Author: United Nations Publications
Publisher:
ISBN:
Category : Business & Economics
Languages : en
Pages : 158
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Book Description
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.
Author: Mr.Victor Thuronyi
Publisher: International Monetary Fund
ISBN: 9781557755872
Category : Business & Economics
Languages : en
Pages : 534
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Book Description
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.
