Source Versus Residence PDF Download
Are you looking for read ebook online? Search for your book and save it on your Kindle device, PC, phones or tablets. Download Source Versus Residence PDF full book. Access full book title Source Versus Residence by Michael Lang. Download full books in PDF and EPUB format.
Author: Michael Lang
Publisher:
ISBN: 9789041127631
Category : Aliens
Languages : en
Pages : 0
Get Book Here
Book Description
The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Author: Michael Lang
Publisher:
ISBN: 9789041127631
Category : Aliens
Languages : en
Pages : 0
Get Book Here
Book Description
The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Author: Eric Kemmeren
Publisher:
ISBN: 9789087227111
Category : Double taxation
Languages : en
Pages : 380
Get Book Here
Book Description
This publication gives a global overview of international tax disputes on double tax conventions. It covers the 32 most important tax treaty cases which were decided around the world in 2019. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases.
Author: Jaivir Singh
Publisher: Berghahn Books
ISBN: 9788187358282
Category : Business & Economics
Languages : en
Pages : 266
Get Book Here
Book Description
A Large Body Of Standard Literature On Regulation Has Grown Organically In Response To The Markets In The United States And Western Europe. The Twelve Papers In Regulation, Institutions And The Law Try To Understand The Specific Context Within Which Regulation Has Unfolded In A Country Like India, Which Is Different In Many Ways From That Of The United States And Western Europe. The Volume Also Dwells On How These Regulatory Issues Flow Across National Boundaries And Affect The International Arena In This Age Of Globalization. Jaivir Singh Teaches At The Centre For The Study Of Law And Governance, Jawaharlal Nehru University, New Delhi. He Has Published Articles On The Economics Of Labour Law, Competition Policy, Regulation, Legal Procedure, Judicial Activism And Separation Of Powers, And Is The Author Of 'Central Government Policies: Interface With Competition Policy Objectives' In Pradeep S. Mehta Ed., Towards A Functional Competition Policy For India (Jaipur: Cuts International 2005).
Author: Dale Pinto
Publisher: IBFD
ISBN: 9076078564
Category : Electronic commerce
Languages : en
Pages : 260
Get Book Here
Book Description
The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment.
Author:
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 52
Get Book Here
Book Description
Author: Anna Binder
Publisher: Linde Verlag GmbH
ISBN: 3709410398
Category : Law
Languages : en
Pages : 642
Get Book Here
Book Description
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.he OECD's BEPS project on the UN Model.
Author: Ajit Kumar Singh
Publisher: Kluwer Law International B.V.
ISBN: 9403533641
Category : Law
Languages : en
Pages : 234
Get Book Here
Book Description
In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
Author: Mr.Parthasarathi Shome
Publisher: International Monetary Fund
ISBN: 9781557754905
Category : Business & Economics
Languages : en
Pages : 336
Get Book Here
Book Description
Edited by Parthasarathi Shome, this Handbook was written primarily for economists who are responsible for analyzing and evaluating economic policies of developing countries at an applied level, and who would benefit from a comprehensive discussion of the concepts, principles, and prevailing issues of taxation.
Author: Robert F. Conrad
Publisher: World Bank Publications
ISBN:
Category : Capital investments
Languages : en
Pages : 51
Get Book Here
Book Description
For tax policy to encourage maximum investment of capital (both foreign and domestic) it is necessary to take into account the potential mobility of capital across international borders. Economic analysis of investment incentives should therefore incorporate the effects of variables such as source rules, nexus rules, attribution rules, foreign tax credits, and so on, in addition to traditional variables such as legal tax rates and the revenue implications of the distribution of the tax base.
Author: Jacob A. Frenkel
Publisher: MIT Press
ISBN: 9780262061438
Category : Business & Economics
Languages : en
Pages : 268
Get Book Here
Book Description
In this book the authors provide a new treatment of international taxation, one that focuses on the interactions between fiscal policies of sovereign nations and the magnitude and directions of international capital and goods flow in an integrated world economy.
