Limitation On Benefits Article 16 Of The New Double Taxation Convention Between The United States Of America And The Federal Republic Of Austria
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Author | : |
Publisher | : |
Total Pages | : 170 |
Release | : 1997 |
Genre | : |
ISBN | : |
Download Limitation on Benefits - Article 16 of the New Double Taxation Convention Between the United States of America and the Federal Republic of Austria Book in PDF, Epub and Kindle
Doctoral thesis describing the history and development of limitation on benefits provisions, a detailed account of the tests follows and the concluding chapter deals with the effect of EC law on such provisions. Contains extensive bibliography.
Author | : Félix Alberto Vega Borrego |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 338 |
Release | : 2016-04-24 |
Genre | : Law |
ISBN | : 9041161430 |
Download Limitation on Benefits Clauses in Double Taxation Conventions Book in PDF, Epub and Kindle
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 |
Publisher | : |
Total Pages | : 16 |
Release | : 1954 |
Genre | : Double taxation |
ISBN | : |
Download Convention on Double Taxation with the Federal Republic of Germany Book in PDF, Epub and Kindle
Author | : Germany |
Publisher | : |
Total Pages | : 56 |
Release | : 2006 |
Genre | : Double taxation |
ISBN | : |
Download Protocol amending tax convention with Germany Book in PDF, Epub and Kindle
Author | : United States. Congress. Joint Committee on Taxation |
Publisher | : |
Total Pages | : 74 |
Release | : 1997 |
Genre | : Business & Economics |
ISBN | : |
Download Explanation of Proposed Income Tax Treaty Between the United States and the Republic of Austria Book in PDF, Epub and Kindle
Author | : Austria |
Publisher | : |
Total Pages | : 14 |
Release | : 1986 |
Genre | : Double taxation |
ISBN | : |
Download Double Taxation, Estates, Inheritances, Gifts and Generation-skipping Transfers Book in PDF, Epub and Kindle
Author | : |
Publisher | : |
Total Pages | : 150 |
Release | : 1995 |
Genre | : |
ISBN | : |
Download Article 26 - Limitation of Benefits in the New US-NL Tax Treaty Book in PDF, Epub and Kindle
Booklet aimed at practitioners seeking to apply the convention to US source income flowing to the Netherlands. The text of Article 26 and a reprint of the most relevant documents are appended.
Author | : International Bureau of Fiscal Documentation |
Publisher | : |
Total Pages | : 602 |
Release | : 1998 |
Genre | : Finance |
ISBN | : |
Download Bulletin for International Fiscal Documentation Book in PDF, Epub and Kindle
Author | : Netherlands |
Publisher | : |
Total Pages | : 24 |
Release | : 1969 |
Genre | : Double taxation |
ISBN | : |
Download Tax Convention with the Netherlands Book in PDF, Epub and Kindle
Author | : |
Publisher | : |
Total Pages | : 52 |
Release | : 1998 |
Genre | : Aliens |
ISBN | : |
Download U.S. Tax Guide for Aliens Book in PDF, Epub and Kindle