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Author: Peter H. Rohn
Publisher:
ISBN:
Category :
Languages : en
Pages : 821
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Book Description
Author: Peter H. Rohn
Publisher:
ISBN:
Category :
Languages : en
Pages : 821
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Book Description
Author: Arvid Aage Skaar
Publisher: Kluwer Law International B.V.
ISBN: 9403520647
Category : Law
Languages : en
Pages : 999
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Book Description
A new edition of the preeminent work on the permanent establishment (PE) is a major event in tax law scholarship. Taking into account changes in judicial and administrative practice as well as the Organisation for Economic Co-operation and Development’s (OECD’s) and the United Nation’s (UN’s) work in the three decades since the first edition, the present study brings the analysis up to date with the current internationally accepted interpretation of PE. The analysis is based on more than 720 cases from more than 20 countries, in addition to the OECD and UN model treaties and more than 630 books, articles, and official documents. The increased significance of the digital economy has rendered the traditional concept of PE inadequate for the allocation of taxing jurisdiction over the modern, mobile or digital international business. The author’s in-depth analysis explains the legal elements of the PE principle with attention to their continuing benefit and their shortcomings: criteria defining a PE- place of business, location, right of use, duration, business connection, business activity, ordinary course of business; evidence of a right of use to a place of business; business activities included in the PE concept of the tax treaties; identification of projects offshore and onshore; UN model treaty deviations from the OECD agency clause; distinction between jurisdictions with significant natural resources and countries possessing the capital, technology and know-how necessary to explore and exploit these resources; and how policies in each country may erode the PE concept. The book provides many synopses of court decisions and administrative rulings upon which the analysis is based. In addition to cases previously published in law reports and other publications, a number of unpublished decisions are included. A key word index makes it easy to find what is needed in any particular matter. The PE principle, in one version or another, is used in several thousand tax treaties in force today. This updated comprehensive study reveals the obligations imposed through the use of PE in tax treaties and will continue to be of immeasurable value to tax practitioners and scholars worldwide. In addition, the discussion of whether the notion of PE is an appropriate criterion for taxing jurisdiction in international fiscal law today provides authoritative and insightful food for thought.
Author: Peter H. Rohn
Publisher: Santa Barbara, Calif. : ABC-Clio, Incorporated
ISBN:
Category : Political Science
Languages : en
Pages : 390
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Book Description
Author: Richard K. Gardiner
Publisher: Oxford University Press, USA
ISBN: 0199669236
Category : Law
Languages : en
Pages : 577
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Book Description
The rules of treaty interpretation codified in the 'Vienna Convention on the Law of Treaties' now apply to virtually all treaties, in an international context as well as within national legal systems, where treaties have an impact on a large and growing range of matters. The rules of treaty interpretation differ somewhat from typical rules for interpreting legal instruments and legislation within national legal systems. Lawyers, administrators, diplomats, and officials at international organisations are increasingly likely to encounter issues of treaty interpretation which require not only knowledge of the relevant rules of interpretation, but also how these rules have been, and are to be, applied in practice. Since the codified rules of treaty interpretation came into decree, there is a considerable body of case-law on their application. This case-law, combined with the history and analysis of the rules of treaty interpretation, provides a basis for understanding this most important task in the application of treaties internationally and within national systems of law. Any lawyer who ever has to consider international matters, and increasingly any lawyer whose work involves domestic legislation with any international connection, is at risk nowadays of encountering a treaty provision which requires interpretation, whether the treaty provision is explicitly in issue or is the source of the relevant domestic legislation. This fully updated new edition features case law from a broader range of jurisdictions, and an account of the work of the International Law Commission in its relation to interpretative declarations. This book provides a guide to interpreting treaties properly in accordance with the modern rules.
Author: Marci Hoffman
Publisher: Martinus Nijhoff Publishers
ISBN: 9004204814
Category : Law
Languages : en
Pages : 412
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Book Description
A special course adoption price is available for an order of six or more copies from a university bookstore. Contact
[email protected]>
[email protected] or
[email protected]. International and Foreign Legal Research: A Coursebook, by Marci Hoffman and Mary Rumsey, now in a second, revised edition, is designed for classes in foreign and international legal research. Following a general section on basic concepts, topics covered in the book range from treaty research to chapters on particular subjects of international law. Coverage also includes chapters on researching foreign and comparative law as well as major international organizations, including the UN and the EU. International and Foreign Legal Research offers a possible roadmap for structuring a class in international and foreign legal research while also serving as a tool for quick look-ups when a researcher requires direction on a topic or information on a source. Developed for use in legal research courses, International and Foreign Legal Research is an invaluable resource for librarians, students, law professors, and other researchers in the research of foreign and international law.
Author: Duncan B. Hollis
Publisher:
ISBN: 019884834X
Category : Law
Languages : en
Pages : 897
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Book Description
This guide is an authoritative reference point for anyone interested in the creation or interpretation of treaties and other forms of international agreement. It covers the rules and practices surrounding their making, interpretation, and operation, and uses hundreds of real examples to illustrate different approaches treaty-makers can take.
Author:
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 260
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Book Description
Author: Simon Chesterman
Publisher:
ISBN: 0190947845
Category : Law
Languages : en
Pages : 737
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Book Description
This book brings together world experts on the United Nations and international law, to examine not only the content of that legal regime but how it has been transformed since the second half of the twentieth century.
Author: World Intellectual Property Organization
Publisher: WIPO
ISBN: 9280521136
Category : Law
Languages : en
Pages : 6
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Book Description
This brochure explains how the IPC Green Inventory can give direct access to the latest patent information about technologies in a number of fields including alternative energy production, energy conservation, transportation, waste management, and agriculture and forestry
Author: National Wildlife Federation
Publisher: Lyons Press
ISBN:
Category : Nature
Languages : en
Pages : 636
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Book Description
The Lyons Press is proud to present the forty-fifth annual edition of the National Wildlife Federation's "Conservation Directory" of U.S. and international organizations and agencies working to protect the environment -- the most vital resource of its kind. Included are: members of the United States Congress; government agencies; citizens' groups; educational institutions; databases, services, periodicals, and other directories; federally protected conservation areas; indexes; and more. This annual directory is essential for colleges and universities, libraries, environmental activists, students, outdoor writers, science editors, natural-resource agencies, those seeking employment in the field of conservation, researchers, and all individuals interested in wildlife and ecology.
