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Author: Guglielmo Maisto
Publisher:
ISBN: 9789087223618
Category :
Languages : en
Pages : 600
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Book Description
Taxation of Entertainers and Sportspersons Performing Abroad', comprising the proceedings and working documents of an annual seminar held in Milan in November 2015, is a detailed and comprehensive study on the taxation of highly mobile individuals engaged in the artistic and sports sectors. It begins with a comparative analysis of the domestic tax regime of such individuals and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union. 0The book then moves to selected tax treaty issues. In particular, it analyses: (i) the history of article 17 of the OECD Model Tax Convention; (ii) recent developments concerning that article, particularly the 2014 amendments to the Commentary on Article 17 of the OECD Model Convention; (iii) tax treaty issues related to qualification, allocation and apportionment of income derived by entertainers and sportspersons; and (iv) the taxation of income from image rights, sponsorship and advertising.
Author: Guglielmo Maisto
Publisher:
ISBN: 9789087223618
Category :
Languages : en
Pages : 600
Get Book Here
Book Description
Taxation of Entertainers and Sportspersons Performing Abroad', comprising the proceedings and working documents of an annual seminar held in Milan in November 2015, is a detailed and comprehensive study on the taxation of highly mobile individuals engaged in the artistic and sports sectors. It begins with a comparative analysis of the domestic tax regime of such individuals and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union. 0The book then moves to selected tax treaty issues. In particular, it analyses: (i) the history of article 17 of the OECD Model Tax Convention; (ii) recent developments concerning that article, particularly the 2014 amendments to the Commentary on Article 17 of the OECD Model Convention; (iii) tax treaty issues related to qualification, allocation and apportionment of income derived by entertainers and sportspersons; and (iv) the taxation of income from image rights, sponsorship and advertising.
Author: Adrian Shipwright
Publisher: Spiramus Press Ltd
ISBN: 1910151203
Category : Law
Languages : en
Pages : 2433
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Book Description
A detailed guide to the taxation of entertainers and sportspersons to be released in three volumes and electronically. There is no recent publication on this. This publication is for the practitioner and others written by a practitioner who has been an academic. Its design follows his way of working beginning with the basic materials and analysing them for application to any particular case. It is a starting point for the adviser in a hurry. It includes Key Points boxes to help as well as full contents for each Chapter. There are also many tables and checklists. There is often a further detailed analysis including on Article 17 OECD Model Treaty, HMRC’s published views on “Image Rights”, the 1987 Regulations and DTR. There is also a detailed Chapter on Avoidance. It includes many examples. Relevant statutory and related material are included in the text so everything is easily available. Tax law requires an understanding of the legal analysis of the underlying matters. Accordingly, matters such as “Image Rights” or “Personality Rights”, the Economic Torts, Confidentiality and Passing Off are dealt with. There is also a detailed case study at the end intended to bring matters together.
Author: Ekkehart Reimert
Publisher: Kluwer Law International B.V.
ISBN: 9403512849
Category : Law
Languages : en
Pages : 3112
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Book Description
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
Author: Yariv Brauner
Publisher: Edward Elgar Publishing
ISBN: 1788975375
Category : Law
Languages : en
Pages : 417
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Book Description
Capturing the core challenges faced by the international tax regime, this timely Research Handbook assesses the impacts of these challenges on a range of stakeholders, evaluating various paths to reform at a time when international tax policy is a topic high on politicians’ agendas.
Author: Eric Kemmeren
Publisher: Linde Verlag GmbH
ISBN: 3709410061
Category : Law
Languages : en
Pages : 456
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Book Description
A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 35 most important tax treaty cases which were decided around the world in 2017. 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. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2018 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
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: OECD
Publisher: OECD Publishing
ISBN: 9264239081
Category :
Languages : en
Pages : 2289
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Book Description
This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264306994
Category :
Languages : en
Pages : 2624
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Book Description
This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
Author:
Publisher: OCDE
ISBN: 9789264211155
Category : Business & Economics
Languages : en
Pages : 500
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Book Description
This is the ninth edition of the condensed version of the publication entitled Model Tax Convention on Income and on Capital, first published in 1992 and periodically updated since then. This condensed version includes the text of the Model Tax Convention as it read on 15 July 2014 after the adoption of the ninth update by the Council of the OECD. Historical notes included in Volume I of the full version as well as the detailed list of tax conventions between OECD Member countries and the background reports that are included in Volume II of the full version have not been reproduced in this version.
Author: Daniel Sandler
Publisher: Springer
ISBN: 9789041101181
Category : Business & Economics
Languages : en
Pages : 0
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Book Description
The Taxation of International Entertainers and Athletes: All the World's a Stage provides a comprehensive and detailed analysis of the taxation of non-resident entertainers and athletes in seven countries: Australia, Canada, France, Germany, Japan, the United Kingdom and the United States. The book deals with the many sources of income which such individuals can derive, including income from live performances, television appearances, commercials, product endorsements, royalties for record sales or `needle time', and merchandising of concert paraphernalia. The primary focus of the book is income tax, although VAT regimes are also considered. In addition, the book provides in-depth analysis of Article 17 (Artists and Sportsmen) of the OECD Model Tax Treaty, particularly regarding the extensive additions to the Commentary to that Article made in 1992 based on the OECD's 1987 report on the taxation of entertainers and athletes. The book contains a table summarising the tax treaty provisions applicable to personal services income derived by entertainers and athletes in the seven countries reviewed. Two examples (one dealing with a touring pop group and the other with a professional tennis player) are used to illustrate, compare and contrast the manner in which income earned by non-resident entertainers and athletes is treated under domestic income tax and VAT regimes (where applicable) in these countries. Finally, conclusions are drawn, at the domestic and international levels, regarding policy and practical considerations in the effective and efficient taxation of such individuals.
