Tax Treaty Case Law Around the Globe, 2011 PDF Download
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Author: Michael Lang
Publisher:
ISBN: 9789041138767
Category : Conflict of laws
Languages : en
Pages : 0
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Book Description
Although tax treaties may look similar because they are usually based on model tax conventions, clear differences in interpretation and application become evident in the diversity of court decisions on tax treaty issues worldwide. In this book, outstanding experts from over thirty jurisdictions discuss the most relevant recent court decisions taken in their countries. The contributions, focusing on the potential impact of the judgments on the interpretation and application of tax treaties in other countries, cover such important aspects as the following: residence requirements; cross-border partnerships; characterization of interest payments; transfer pricing; royalties; directors' fees; artistes' and sportsmen's income; students' income; and ; compensation of losses. Each discussion gives the facts of each case (many of the cases are not accessible in English), the reasoning of the court, and the author's observations. The systematic structure of each report allows different tax treaty case law to be studied and compared in a simple and efficient way - something that has never been done this comprehensively before.
Author: Michael Lang
Publisher:
ISBN: 9789041138767
Category : Conflict of laws
Languages : en
Pages : 0
Get Book Here
Book Description
Although tax treaties may look similar because they are usually based on model tax conventions, clear differences in interpretation and application become evident in the diversity of court decisions on tax treaty issues worldwide. In this book, outstanding experts from over thirty jurisdictions discuss the most relevant recent court decisions taken in their countries. The contributions, focusing on the potential impact of the judgments on the interpretation and application of tax treaties in other countries, cover such important aspects as the following: residence requirements; cross-border partnerships; characterization of interest payments; transfer pricing; royalties; directors' fees; artistes' and sportsmen's income; students' income; and ; compensation of losses. Each discussion gives the facts of each case (many of the cases are not accessible in English), the reasoning of the court, and the author's observations. The systematic structure of each report allows different tax treaty case law to be studied and compared in a simple and efficient way - something that has never been done this comprehensively before.
Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709409101
Category : Law
Languages : en
Pages : 417
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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 forty-one most important tax treaty cases which were decided around the world in 2016. 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, the proposed book is a valuable reference tool for all tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics who are active in tax treaty case law.
Author: Eric Kemmeren
Publisher: Linde Verlag GmbH
ISBN: 3709413281
Category : Law
Languages : en
Pages : 480
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Book Description
A Global Overview of International Tax Disputes on DTC This book is a unique publication that provides a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases that were decided around the world in 2021. 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 2022 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Author: Georg Kofler
Publisher: Linde Verlag GmbH
ISBN: 3709412331
Category : Law
Languages : en
Pages : 332
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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 thirty most important tax treaty cases that were decided around the world in 2020. 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 2021" 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: Eric Kemmeren
Publisher: Linde Verlag GmbH
ISBN: 3709408601
Category : Law
Languages : en
Pages : 423
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Book Description
A Global Overview of International Tax Disputes on DTC This book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases which were decided in 2015 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes. With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2016 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics.
Author: Eric Kemmeren
Publisher: Linde Verlag GmbH
ISBN: 3709411912
Category : Law
Languages : en
Pages : 402
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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 in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that 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. With the continuously increasing importance of tax treaties, “Tax Treaty Case Law around the Globe 2020” is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709411017
Category : Law
Languages : en
Pages : 322
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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 forty-one most important tax treaty cases which were decided around the world in 2018. 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 2019 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: Eric Kemmeren
Publisher: Linde Verlag GmbH
ISBN: 370941007X
Category : Law
Languages : en
Pages : 362
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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: Georg Kofler
Publisher: Linde Verlag GmbH
ISBN: 3709413419
Category : Law
Languages : en
Pages : 281
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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 29 most important tax treaty cases that were decided around the world in 2022. 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 2023 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: Sriram Govind
Publisher: Linde Verlag GmbH
ISBN: 3709410754
Category : Law
Languages : en
Pages : 678
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Book Description
Tax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.
