Departures From The Oecd Model And Commentaries
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Author | : Guglielmo Maisto |
Publisher | : |
Total Pages | : 598 |
Release | : 2014 |
Genre | : Double taxation |
ISBN | : 9789087222499 |
Download Departures from the OECD Model and Commentaries Book in PDF, Epub and Kindle
"Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions including Australia, Austria, Belgium, China, Germany, Italy, the Netherlands, Spain and the United States. This book is essential reading for all those dealing with tax treaty issues and EU tax law."--Extracted from publisher website on May 19, 2015.
Author | : K. Cejie |
Publisher | : |
Total Pages | : |
Release | : 2017 |
Genre | : |
ISBN | : |
Download The Commentaries on the OECD Model as a Mechanism for Interpretation with Reference to the Swedish Perspective Book in PDF, Epub and Kindle
This article considers the question of the importance of the Commentaries on the OECD Model and, in particular, whether an ambulatory or a static approach to changes in the OECD Commentaries should be adopted. The point of departure is international tax law, with an emphasis on the Swedish perspective. Recent case law from the Supreme Administrative Court is also considered.
Author | : Eric Kemmeren |
Publisher | : Linde Verlag GmbH |
Total Pages | : 394 |
Release | : 2019-06-13 |
Genre | : Law |
ISBN | : 370941007X |
Download Tax Treaty Case Law around the Globe 2018 Book in PDF, Epub and Kindle
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 | : |
Publisher | : |
Total Pages | : |
Release | : 1977 |
Genre | : |
ISBN | : |
Download Text of the OECD Model Convention : Commentaries on the Articles of the OECD Model Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital : Amendments to the Commentaries on Articles 9, 10, 11 and 12 of the OECD Model Convention for the Avoidance of Double Taxation with Respect to Taxes on Income and on Capital Book in PDF, Epub and Kindle
Author | : Desiree Auer |
Publisher | : Linde Verlag GmbH |
Total Pages | : 496 |
Release | : 2021-09-21 |
Genre | : Law |
ISBN | : 3709411602 |
Download Access to Treaty Benefits Book in PDF, Epub and Kindle
A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty benefits in a holistic way and view the recent trends through a wide lens. All chapters contain a complete examination of the relevant topics, starting from a historical perspective and continuing with tax treaty law principles and tax practice analysis. Where appropriate, a domestic law and domestic courts’ jurisprudence perspective was added as well as a comparative analysis of several jurisdictions thus complementing the examination of each topic. Finally, special attention is given to treaty abuse and the new GAAR introduced in the 2017 OECD Model together with its interrelation with other treaty and domestic anti-abuse provisions and the impact of these provisions on tax treaty access and tax policy in general.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 2289 |
Release | : 2015-10-30 |
Genre | : |
ISBN | : 9264239081 |
Download Model Tax Convention on Income and on Capital 2014 (Full Version) Book in PDF, Epub and Kindle
This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014.
Author | : Tiago Gonçalves Marques |
Publisher | : Leya |
Total Pages | : 397 |
Release | : 2023-04-21 |
Genre | : Law |
ISBN | : 9899160016 |
Download The New Permanent Establishment Book in PDF, Epub and Kindle
This work is the result of an extensive research into the permanent establishment concept, a concept that plays a vital role within the international taxation system through the fair allocation of taxing rights over cross-border business profits in the context of the tenuous balance between the residence and source principles, as a threshold for source taxation. Our research sought to explore and explain the evolution of this concept in the context of recent changes resulting from the joint work of the G20 and the OECD, namely under the aegis of the BEPS Project (Action 7), and later with the enactment of the Multilateral Instrument and the update to the OECD Model Convention. We also address the Portuguese permanent establishment concept and, finally, the future of the permanent establishment concept within the international taxation system.
Author | : Chester Brown |
Publisher | : Oxford University Press |
Total Pages | : 1018 |
Release | : 2013-01-17 |
Genre | : Law |
ISBN | : 0199645191 |
Download Commentaries on Selected Model Investment Treaties Book in PDF, Epub and Kindle
Model Bilateral Investment Treaties (BITs) are a state's blueprint for the investment treaties it negotiates with other states. This book compiles commentaries on the Model BITs of 19 key jurisdictions. It analyses state practice on international investment law, detailing each state's legislative regime on foreign investment and their BIT programme
Author | : Adolfo Martin Jimenez |
Publisher | : |
Total Pages | : 0 |
Release | : 2014 |
Genre | : |
ISBN | : |
Download The 2003 Revision of the OECD Commentaries on the Improper Use of Tax Treaties Book in PDF, Epub and Kindle
This article examines the OECD's new position regarding the improper use/abuse of double taxation treaties introduced in the January 2003 revision of the OECD Model Tax Convention and Commentaries. Although the most important changes were added in the Commentary on Art. 1 of the OECD Model, other articles or their Commentary have also been affected. This article first focuses on the new Commentary added to Art. 1 on the improper use of tax treaties and the Commentaries on the other articles closely related it. The article next studies the new commentaries and changes to the OECD Model which deal with topics relating to access to tax treaties and their improper use. The article then summarizes this author's opinion on the new Commentaries on the improper use/abuse of tax treaties and also connects the first sections of the article to another part which considers whether the Commentaries added in 2003 affect prior treaties. This includes some general thoughts on whether the effect of the OECD Commentaries on treaty interpretation is overestimated and whether the Commentaries should be downgraded in their effect on treaties because they affect taxpayers' rights. Some reflections on how to improve the declining effect of the OECD Commentaries close this work.
Author | : Alicja Majdanska |
Publisher | : Linde Verlag GmbH |
Total Pages | : 740 |
Release | : 2018-09-14 |
Genre | : Law |
ISBN | : 3709409586 |
Download OECD Arbitration in Tax Treaty Law Book in PDF, Epub and Kindle
Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes.