The Anti-abuse Rule for Permanent Establishments Situated in Third States 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 The Anti-abuse Rule for Permanent Establishments Situated in Third States PDF full book. Access full book title The Anti-abuse Rule for Permanent Establishments Situated in Third States by Jean-Philippe Van West. Download full books in PDF and EPUB format.
Author: Jean-Philippe Van West
Publisher:
ISBN: 9789087226398
Category :
Languages : en
Pages :
Get Book Here
Book Description
Author: Jean-Philippe Van West
Publisher:
ISBN: 9789087226398
Category :
Languages : en
Pages :
Get Book Here
Book Description
Author: Carlo Garbarino
Publisher: Edward Elgar Publishing
ISBN: 1788976894
Category : Corporations
Languages : en
Pages : 375
Get Book Here
Book Description
The OECD’s guidance on combatting tax avoidance strategies associated with Base Erosion and Profit Sharing (BEPS) methods is complex and accompanied by a wealth of literature. This book is the first to provide a concise and accessible overview of counter BEPS measures in the OECD Model and Commentary, allowing readers to gain a practical understanding of how the measures can impact the taxation of bilateral investments protected by tax treaties.
Author: Xavier Oberson
Publisher: IBFD
ISBN: 9087220987
Category : Double taxation
Languages : en
Pages : 457
Get Book Here
Book Description
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Author: Jean-Philippe Van West
Publisher:
ISBN: 9789087226381
Category :
Languages : en
Pages :
Get Book Here
Book Description
Author: OCDE,
Publisher: OCDE
ISBN: 9789264241213
Category : Double taxation
Languages : en
Pages : 48
Get Book Here
Book Description
This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264241221
Category :
Languages : en
Pages : 51
Get Book Here
Book Description
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 7.
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:
Publisher:
ISBN:
Category : Capital gains tax
Languages : en
Pages : 52
Get Book Here
Book Description
Author: Kevin Holmes
Publisher: IBFD
ISBN: 9087220235
Category : Double taxation
Languages : en
Pages : 433
Get Book Here
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: OECD
Publisher: OECD Publishing
ISBN: 9264162941
Category :
Languages : en
Pages : 82
Get Book Here
Book Description
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
