International Taxation Of Income From Services Under Double Taxation Conventions

Author by : Marta Castelon
Languange : en
Publisher by : Kluwer Law International B.V.
Format Available : PDF, ePub, Mobi
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Total Download : 668
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Description : The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This multiple-award-winning book is an indispensable tool for practitioners and a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers the rst in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following: – the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; – relationships among the MLI, the Model DTCs, and speci c DTCs; – development of the provisions dealing with services in the DTCs; – how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; – opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; – practical questions about the taxation of different distribution models – from fully edged distributors to commissionaires; – challenges and proposals relating to the differentiation between various types of services under DTCs; – the permanent establishment concept; – to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); – how changes in the US Model DTC of 2016 affect international service provisions; and – proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the ‘BEPS package’ and its subsequent MLI. This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years. Interested academics too will bene t from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.


International Tax Primer

Author by : Brian J. Arnold
Languange : en
Publisher by : Kluwer Law International B.V.
Format Available : PDF, ePub, Mobi
Total Read : 19
Total Download : 386
File Size : 52,9 Mb
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Description : International Tax Primer provides an introduction to the policies that countries seek to advance with their international tax rules, with numerous examples drawn from the practices of both developed and developing countries. This third edition has been expanded substantially, due to the major developments that have occurred since the second edition of this indispensable resource appeared in 2004 – not least the fact that innumerable smalland medium-sized firms, as well as individuals, now engage in cross-border transactions that cause them and their tax advisers to confront international tax issues on a regular basis. Moreover, as the countries of the world have become increasingly integrated economically, the importance of the major issues that a country must confront in designing its international tax rules and in coordinating those rules with the tax systems of its trading partners has mushroomed. The book strikes a balance between the specific and the general by illustrating the funda mental principles and structure of international tax with frequent reference to actual practice in a variety of countries. Coverage includes the following: • role of the tax adviser in planning international transactions; • taxation of residents on foreign income and of non-residents on domestic income; • mechanisms used to mitigate the risks to taxpayers of international double taxation; • transfer pricing rules to prevent the avoidance of tax by multinational corporations; • anti-avoidance measures dealing with tax havens, treaty shopping, and other offensive tax planning activities; • overview and analysis of the provisions of bilateral tax treaties and the OECD and UN • Model Treaties on which they are generally based; and • challenges posed by taxation of income derived from the digital economy. New material in the third edition includes analysis of the OECD’s initiative against base erosion and profit shifting (BEPS), tax aspects of hybrid entities and financial instruments, and taxation of fees for technical services as proposed under the UN Model Treaty. Although of greatest value to tax practitioners and government officials confronting interna tional tax for the first time, this book is sure to continue in use by tax professionals at every level of experience and on a worldwide basis.


International Double Taxation

Author by : Mogens Rasmussen
Languange : en
Publisher by : Kluwer Law International B.V.
Format Available : PDF, ePub, Mobi
Total Read : 22
Total Download : 781
File Size : 49,8 Mb
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Description : Practical introduction to the law of income and capital tax conventions based on the OECD Convention as well as selected legislation and case law. After an introduction, the chapters deal with the OECD Model, the UN Model, provisions which are not included in the model conventions (technical fees, professors, teachers and researchers, activities in connection with preliminary surveys, exploration or extraction of hydrocarbons, tax sparing, most-favoured nation clause, taxation of services), agreements containing a single provision concerning exchange of information, new wording of article 7 in the 2010-update of the OECD Model, and changes in the commentaries in the 2010-update of the OECD Model.


Tax Treaty Case Law Around The Globe 2020

Author by : Eric Kemmeren
Languange : en
Publisher by : Linde Verlag GmbH
Format Available : PDF, ePub, Mobi
Total Read : 31
Total Download : 799
File Size : 55,5 Mb
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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


Introduction To The Law Of Double Taxation Conventions

Author by : Michael Lang
Languange : de
Publisher by : Linde Verlag GmbH
Format Available : PDF, ePub, Mobi
Total Read : 9
Total Download : 206
File Size : 42,7 Mb
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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.


Model Income Tax Treaties

Author by : Kees van Raad
Languange : en
Publisher by : Springer
Format Available : PDF, ePub, Mobi
Total Read : 25
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File Size : 50,5 Mb
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Description : In this booklet a comparative survey is offered offour model income tax conventions: the OECD drafts of 1963 and 1977, the United Nations Model of 1980 and the proposed United States Treasury's model of 1981. In order to facilitate the compari son, the text of the 1977 OECD draft is used as reference. Additions and alternatives in any of the other models to this 1977 OECD text are italicized. Omissions from the 1977 OECD model in the other drafts are indicated either by a blank space (where an entire paragraph has been suppressed) or by brackets [] ( in case of smaller omissions). The Hague, May 1983 Kees van Raad OECD 1963 OECD 1977 OECD DRAFT DOUBLE TAXA OECD MODEL DOUBLE TAXA TION CONVENTION ON INCOME TION CONVENTION ON INCOME AND CAPITAL AND CAPITAL 1963 1977 TITLE[] TITLE OF THE CONVENTION Convention between (State A) and (State Convention between (State A) and (State B) for the avoidance of double taxation B) for the avoidance of double taxation with respect to taxes on income and on with respect to taxes on income and m capital capital 1 PREAMBLE OF THE CONVENTION CHAPTER I CHAPTER I SCOPE OF THE CONVENTION SCOPE OF THE CONVENTION Article 1 Article 1 PERSONAL SCOPE PERSONAL SCOPE This Convention shall apply to persons This Convention shall apply to persons who are residents of one or both of the who are residents of one or both of the Contracting States. Contracting States.


Non Discrimination And Trade In Services

Author by : Catherine A. Brown
Languange : en
Publisher by : Springer
Format Available : PDF, ePub, Mobi
Total Read : 82
Total Download : 233
File Size : 52,6 Mb
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Description : This book argues that the proliferation of global trade and the increasing power of free trade arrangements leave income taxes as one of the few remaining measures that can potentially be used for protectionist purposes. It analyzes the interaction between the non-discrimination principles in tax treaties and trade-related agreements including multilateral (WTO), regional (NAFTA, AANZTA) and bilateral free trade agreements. The absence of a non-discrimination obligation with respect to tax measures that apply to non-resident service providers and to non-resident services may, therefore, significantly undermine trade obligations. The book clearly reveals how these tax barriers to trade may unfairly or unnecessarily restrict trade in services, and puts forward a new, more effective non-discrimination obligation in tax matters to be included in tax treaties, one that would more closely parallel the non-discrimination obligations in trade agreements. The book examines the concept of non-discrimination in tax matters from several perspectives, specifically a North American and Australian perspective, as well as a perspective based on EU (and UK) law, focusing on the interaction between these legal systems, bilateral tax treaties, regional trade agreements and, where relevant, the General Agreement on Trade in Services (GATS). The book explores the possibility of a reciprocal influence between tax treaties and trade agreements, and poses the question as to whether tax treaties might do more in providing a non-discrimination principle in the cross-border trade in services./div


Permanent Establishments

Author by : Ekkehart Reimer
Languange : en
Publisher by : Kluwer Law International B.V.
Format Available : PDF, ePub, Mobi
Total Read : 17
Total Download : 200
File Size : 45,5 Mb
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Description : Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management. Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals. This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective. Contributors: Fabrizio Acerbis, Maret Ansperi, Yumiko Arai, Ákos Burján, Anna Berglund, Peter Collins, Mike Cooper, David Cuellar, Veronika Daurer, Frank Feng, Mikhail Filinov, Sandra Fleurier, Jose Antonio Gonzalez, Herbert Greinecker, Søren Jesper Hansen, Lars Ellegård Holst, Mauricio Hurtado, Martin Jann, Renaud Jouffroy, David Lermer, Peter Lindblad, Iren Lipre, Jessica Ma, Anna Mallol, Dennis Matthijs, Hamish McElwee, Kunal Mehta, Osman Mollagee, Matthew Mui, Ramón Mullerat, Luis Felipe Muñoz, Stephen Nauheim, Francesco Nuzzolo, Yoshiyasu Okada, Marianne Orell, Oren Penn, Martin Poulsen, Lene Munk Rasmussen, Ekkehart Reimer, Daniel Rinke, Stefan Schmid, Mathias Schreiber, Vishal J. Shah, Smit Sheth, Tom Stuer, Maarten Temmerman, Eszter Turcsik, Hein Vermeulen, Huili Wang, Sonia Watson, Ciska Wisman, Raymond Wong & Alan Yam.


Interpretation And Application Of Tax Treaties In North America

Author by : Anonim
Languange : en
Publisher by : IBFD
Format Available : PDF, ePub, Mobi
Total Read : 42
Total Download : 578
File Size : 51,7 Mb
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Description : The interpretation of tax treaties has never been easy. Sometimes we simply need to understand the mentality of the person when they interpret and apply a tax treaty. For example, what can be good faith for some people can be treaty override for their counterparts. Certainly the courts in Canada, the United States and Mexico have reasoned all of their tax treaty interpretation cases in a different manner. Thus, it is possible that if a case is resolved in one court, the ruling may be different had the same case been brought to a court in another country. More than 100 countries have a tax treaty concluded with Canada, the United States or Mexico. As such, it is helpful for tax practitioners worldwide to understand the criteria used by the courts in these countries when interpreting a tax treaty. This book presents the reader with an in-depth overview of the materials, court cases and mutual agreement procedures implemented in these three countries. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties


Essays On International Taxation

Author by : Dhruv Sanghavi
Languange : en
Publisher by : Bloomsbury Publishing
Format Available : PDF, ePub, Mobi
Total Read : 40
Total Download : 587
File Size : 43,6 Mb
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Description : Fiscally transparent entities and tax treaty eligibility Shefali Goradia Triangular cases – the neglected problem in tax treaty law Michael Lang Can tax treaty entitlement provisions for hybrid entities be refined? Dhruv Sanghavi Non-discrimination provisions in tax treaties Ajay Vohra Two to tango: a dance of substance and form Bijal Ajinkya Deconstructing Principal Purpose Test under Article 7 of MLI Mukesh Butani Preventing treaty abuse in the context of multilateral instrument Dinesh Kanabar and Saurabh Shah Taxation of digital economy – the journey, India and across the world Daksha Baxi Digitalisation of the economy: Our perspective on the OECD's Unified Approach Vikram Chand Reflections on the 2019 OECD proposal on Pillar One Guglielmo Maisto Implementation of BEPS and Amendments to Section 9 Radhakishan Rawal Public international law, object and purpose, MLI, BEPS and the OECD Model Tax Convention Clive M. Baxter Tax laws through a constitutional prism Arvind P. Datar Tax policy as a tool to enable impact investment and improve CSR targeting Meyyappan Nagappan and Nehal Binani Tax system design - an analysis of some design choices made by the Indian Income Tax Act, 1961 Shreya Rao Through the looking glass: resolving tax disputes by arbitration under a bilateral investment treaty H. David Rosenbloom


Income Tax Treaties

Author by : Jon E. Bischel
Languange : en
Publisher by : Practising Law Inst
Format Available : PDF, ePub, Mobi
Total Read : 42
Total Download : 845
File Size : 44,6 Mb
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Description : Compilation of studies in the field of international taxation in United States bilateral tax treaties with other countries (the United Kingdom, France, Germany and Japan) as well as a description of structure and operation of tax treaties in general.


International Taxation Of Cloud Computing

Author by : Alexander Weisser
Languange : en
Publisher by : Éditions juridiques libres / Freier juristischer Verlag
Format Available : PDF, ePub, Mobi
Total Read : 76
Total Download : 591
File Size : 54,6 Mb
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Description : Cloud computing may be borderless, but taxes are territorial. It is easy to imagine how the two concepts can clash. Much effort has gone into harmonizing tax rules across borders with the result that many jurisdictions have very similar tax rules. Even so, taxation remains a basic expression of national sovereignty. The goal of this thesis is to examine how international tax law applies to the cross-border cloud computing business. Both, multinational providers and customers of cloud computing services are analyzed. Reflecting three traditional areas of international tax scholarship, the goal could be stated in three questions. Which jurisdictions have the right to tax? What kinds of cloud computing transactions can be taxed? What amount of the profit is taxable? In more technical terms, this means enquiring into how the use of cloud computing affects the permanent establishment status of taxpayers, how the different kinds of cloud computing transactions are characterized under international double taxation treaties, and how the calculation of taxable cloud computing profit is affected by transfer pricing. In light of the current political events, the thesis also offers recommendations de lege lata through a systematic approach. Its first part assesses the current taxation of cloud computing. The second part evaluates whether the findings of this initial assessment conform to various superior principles of good rulemaking. It identifies which of the present tax rules ought to be adapted. The final part considers how the rules could be amended to become more compliant with the superior principles. In this way, Part I embodies the thesis, Part II the antithesis, and Part III seeks a synthesis.


Chinese Tax Law And International Treaties

Author by : Lorenzo Riccardi
Languange : en
Publisher by : Springer Science & Business Media
Format Available : PDF, ePub, Mobi
Total Read : 94
Total Download : 559
File Size : 46,5 Mb
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Description : The People’s Republic of China’s tax policies and international obligations are as multifaceted and dynamic as they are complex, developing closely with the nation’s rise to the world’s fastest-growing major economy. Today, after decades of reform and the entry into the World Trade Organization, China has developed regulatory systems that enable it to provide stable administration, including a tax structure. China’s main tax reform can be attributed to the enactment of the Enterprise Income Tax Law, which came into effect on January 1, 2008. Chinese tax regulations include direct taxes, indirect taxes, other taxes, and custom duties and from a collection point of view, China’s tax administration adopts a very devolved system, with revenue collected and shared between different levels of government in accordance with contracts between the different levels of the tax administration system. With respect to international treaties, China has established a network of bilateral tax treaties and regional free trade agreements. This publication describes in detail China’s complex tax system and policies, as well as major bilateral treaties in which China has entered into using country-by-country analysis. Lorenzo Riccardi is Tax Advisor and Certified Public Accountant specialized in international taxation. He is based in Shanghai, where he focuses on business and tax law, assisting foreign investments in East Asia. He is an auditor and an advisor for several corporate groups and he is partner and Head of Tax of the consulting firm GWA, specializing in emerging markets.


Tax Treaty Case Law Around The Globe 2019

Author by : Michael Lang
Languange : en
Publisher by : Linde Verlag GmbH
Format Available : PDF, ePub, Mobi
Total Read : 74
Total Download : 806
File Size : 50,9 Mb
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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.


Double Taxation Conventions

Author by : United States. Congress. Senate. Committee on Foreign Relations
Languange : en
Publisher by : Unknown
Format Available : PDF, ePub, Mobi
Total Read : 12
Total Download : 948
File Size : 42,6 Mb
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Description :


Introduction To United States International Taxation

Author by : James R. Repetti
Languange : en
Publisher by : Kluwer Law International B.V.
Format Available : PDF, ePub, Mobi
Total Read : 93
Total Download : 613
File Size : 46,7 Mb
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Description : The new edition of this well-known reference work for the tax community provides an introduction to the application of the United States (US) international taxation system to taxpayers investing or transacting business in the US and other countries. In a relatively brief and manageable form, it sets forth the principles adopted by the US in taxing US or foreign individuals and corporations as they invest, work, or carry on a trade or business in the US or abroad. The presentation focuses on the following aspects of the subject matter: general aspects of the corporation income tax, the individual income tax, the tax treatment of partnerships, trusts, and accounting aspects; the basic jurisdictional principles adopted by the US with respect to application of its income tax to international investment and business transactions; the US rules for taxing foreign corporations, foreign partnerships, foreign trusts, and nonresident aliens on their business and investment income derived from US sources; the basic mechanism adopted by the US to alleviate international double taxation on foreign source income derived by US persons; the income tax treatment of foreign corporations controlled by US shareholders, including the new GILTI minimum tax and exempt dividend rules; the special treatment under FDII of a US corporation’s export of goods, services and intangible rights; the general intercompany pricing rules and special transfer pricing rules applicable to particular transactions; rules for the treatment of transactions involving currencies other than the US dollar; situations in which US income tax treaty provisions modify the basic rules; and the wealth transfer tax system, including modifications made by estate and gift tax treaties. Throughout the discussion, the authors incorporate references not only to the Internal Revenue Code provisions under discussion but also to relevant Treasury Regulations and other administrative material and to important cases that have arisen. For non-US tax practitioners, tax professors and students both within and outside the US, and others seeking a structural framework within which a US tax problem can be placed, Introduction to United States International Taxation offers the ideal reference source.


Cross Border Taxation Of Permanent Establishments

Author by : Andreas Waltrich
Languange : en
Publisher by : Kluwer Law International B.V.
Format Available : PDF, ePub, Mobi
Total Read : 92
Total Download : 146
File Size : 41,6 Mb
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Description : The permanent establishment (PE) is a legal form of cross-border direct investment whereby a business presence is maintained as an integral part of the foreign investor. Due to the growing intensity and complexity of international business relations, the PE defi¬nition and the allocation of profi¬ts between head units and PEs have become highly contentious, especially from the perspectives of the major emerging economies of the BRIC countries (Brazil, Russia, India, and China). Unsurprisingly, the potential for tax avoidance and the scrutiny of tax authorities have increased enormously. Against this background, this work illustrates and compares the OECD Model Tax Convention with country-specifi¬c source taxation rules, focusing on possible tax system changes and offering reform proposals. Emphasizing the taxable implications of the various rules upon country-speci¬fic PE concepts, the author’s treatment covers such issues and topics as the following: – the PE de¬finition of the OECD MC and from the perspective of selected countries; – allocation of business pro¬fits under the Authorised OECD Approach (AOA); – avoidance of PE status; – implementation of a service PE proposal; – construction site PEs established by subcontractors; – existence of an agency PE; and – the OECD project on Base Erosion and Profi¬t Shifting (BEPS). The author uses simulated cross-border national and treaty cases to highlight qualifi¬cation conflicts, thus reinforcing his detailed discussion of source taxation rules of business profi¬ts and relevant case law in Germany, the United States, and the BRIC states. There is also a checklist detailing how companies can avoid unintentionally setting up a PE. The author’s deeply informed proposals provide much-needed guiding tax criteria and open the way to greater feasibility and transparency in PE taxation. Because the defi¬nition of PEs has enlarged and the treatment of profi¬t allocation has become more complex, the clari¬fication of the PE concept presented in this book is of inestimable importance for lawyers, of¬ficials, policymakers, and academics concerned with international business taxation in any jurisdiction.


Tax Treaty Case Law Around The Globe 2017

Author by : Michael Lang
Languange : en
Publisher by : Linde Verlag GmbH
Format Available : PDF, ePub, Mobi
Total Read : 36
Total Download : 698
File Size : 49,5 Mb
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Description : 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 in 2016 around the world.


Tax Treaty Case Law Around The Globe 2018

Author by : Eric Kemmeren
Languange : en
Publisher by : Linde Verlag GmbH
Format Available : PDF, ePub, Mobi
Total Read : 55
Total Download : 840
File Size : 54,5 Mb
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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.


Tax Convention With Slovenia

Author by : Slovenia
Languange : en
Publisher by : Unknown
Format Available : PDF, ePub, Mobi
Total Read : 68
Total Download : 290
File Size : 49,6 Mb
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The Taxation Of Permanent Establishments

Author by : Radhakishan Rawal
Languange : en
Publisher by : Spiramus Press Ltd
Format Available : PDF, ePub, Mobi
Total Read : 73
Total Download : 921
File Size : 41,8 Mb
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Description : The dramatic advances in communications and technology that have taken place in recent years, combined with the progressive development of the Indian economy, have enticed many multi-national companies to tap the rich resources which India has to offer in terms of front-line business support services and customer relations. This has thrust the Indian tax system into the limelight, with multi-nationals and their advisers now needing to become familiar with the relevant aspects of Indian tax law and practice, and in particular, how India approaches the concept of permanent establishment and the circumstances in which a liability to tax in India could arise. This book's principal theme is the taxation of permanent establishments, taking as its starting point the OECD (Organisation for Economic Co-operation and Development) model convention on the avoidance of double taxation, and examining how the Indian courts and India's law-makers have interpreted the rules governing attribution of profits. The book examines the current issues to which the establishment of business centers in India by multi-nationals have given rise, relating how the law is developing to take account of these latest international business trends.


Vietnam Tax Guide

Author by : Lorenzo Riccardi
Languange : en
Publisher by : Springer Science & Business Media
Format Available : PDF, ePub, Mobi
Total Read : 51
Total Download : 973
File Size : 41,9 Mb
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Description : Vietnam is one of the main developing countries experiencing rapid growth in East Asia. As part of ASEAN and strategically located near China and the Mekong region, Vietnam is considered a leading market between Asian and South Asian countries. Its fiscal system has recently been reformed in order to better align rules with the country’s economic development. Vietnam grants tax incentives and fiscal holidays to foreign investors and has concluded a significant number of double taxation treaties with other nations. This book describes in detail Vietnam’s complex tax system and policies, as well as major bilateral treaties in which Vietnam has entered into using country-by-country analysis. ​


Double Taxation

Author by : Indonesia
Languange : en
Publisher by : Unknown
Format Available : PDF, ePub, Mobi
Total Read : 29
Total Download : 123
File Size : 50,6 Mb
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Description :


Research Handbook On International Taxation

Author by : Yariv Brauner
Languange : en
Publisher by : Edward Elgar Publishing
Format Available : PDF, ePub, Mobi
Total Read : 43
Total Download : 136
File Size : 45,9 Mb
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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.


Tax Convention With Venezuela

Author by : Venezuela
Languange : en
Publisher by : Unknown
Format Available : PDF, ePub, Mobi
Total Read : 69
Total Download : 160
File Size : 45,5 Mb
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Description :