Tax Treaty Entitlement 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 Tax Treaty Entitlement PDF full book. Access full book title Tax Treaty Entitlement by Michael Lang. Download full books in PDF and EPUB format.
Author: Michael Lang
Publisher:
ISBN: 9789087225070
Category :
Languages : en
Pages :
Get Book Here
Book Description
Author: Michael Lang
Publisher:
ISBN: 9789087225070
Category :
Languages : en
Pages :
Get Book Here
Book Description
Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709408628
Category : Law
Languages : en
Pages : 260
Get Book Here
Book Description
The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Author: Kiyoshi Nakayama
Publisher: International Monetary Fund
ISBN: 1513577018
Category : Business & Economics
Languages : en
Pages : 27
Get Book Here
Book Description
A well-designed regional tax treaty to which developing countries are signatories will include provisions securing minimum withholding taxes on investment income and technical service fees, a taxing right in respect of capital gains from indirect offshore transfers, and guarding against-treaty shopping. A tax treaty policy framework—national or regional—that specifies the main policy outcomes to be achieved before negotiations commence would enable developing countries with more limited expertise and lower capacity for tax treaty negotiations to avoid concluding problematic tax treaties. This note provides guidance for members of regional economic communities in the developing world on what should and should not be included in a regional tax treaty and how to design on a common tax treaty policy framework for use in negotiations of bilateral tax treaties with nonmembers.
Author: Félix Alberto Vega Borrego
Publisher: Kluwer Law International B.V.
ISBN: 9041161430
Category : Law
Languages : en
Pages : 438
Get Book Here
Book Description
Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, because treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of double taxation conventions, companies must carefully scrutinize and comply with requirements found in the limitation on benefits (LOB) clauses in tax treaties. This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting (BEPS), and relevant new rulings handed down by the European Court of Justice. Among the subjects and topics covered are the following: – definition of the concepts of person and residence provided in the OECD model; – concept of beneficial owner; – application of domestic anti-avoidance rules; – adoption of specific provisions to counter the phenomenon of treaty shopping; – determination of sufficient nexus with the state of residence or a real business purpose;and – possible consequences of the incompatibility of LOB clauses with EU law. This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Author: United States. Congress. Senate. Committee on Foreign Relations
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 54
Get Book Here
Book Description
Author: Netherlands
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 24
Get Book Here
Book Description
Author: Guglielmo Maisto
Publisher: IBFD
ISBN: 9076078920
Category : Double taxation
Languages : en
Pages : 433
Get Book Here
Book Description
This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Author: Sol Picciotto
Publisher: Praeger
ISBN:
Category : Business & Economics
Languages : en
Pages : 424
Get Book Here
Book Description
This book is a study on the historical development and current status of international tax law in several of the world's most important trading economies. The book emphasizes the laws and policies of the United States, Western Europe, the United Nations, and the OECD. Chapter eight contains a discussion of transfer pricing. Chapter ten addresses the internationalization of tax administrations, contains information relating to tax havens, anti-tax haven legislation, transfer pricing, and tax treaties. Other chapters cover the history, principles and policies of international tax laws; the past and present status of the international tax treaty system; international tax avoidance; the problems created by tax deferrals; worldwide unitary tax issues; and global business and international fiscal laws.
Author: Saurabh Jain
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 325
Get Book Here
Book Description
Author: United Nations Conference on Trade and Development. Programme on Transnational Corporations
Publisher: New York : United Nations
ISBN:
Category : Business & Economics
Languages : en
Pages : 744
Get Book Here
Book Description
