Limitation On Benefits Article 16 Of The New Double Taxation Convention Between The United States Of America And The Federal Republic Of Austria PDF Download
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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 | : 48 |
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 | : 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 | : Michael Lang |
Publisher | : Linde Verlag GmbH |
Total Pages | : 266 |
Release | : 2021-04-01 |
Genre | : Law |
ISBN | : 3709408628 |
Download Introduction to the Law of Double Taxation Conventions Book in PDF, ePub and Kindle
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.
Author | : International Bureau of Fiscal Documentation |
Publisher | : |
Total Pages | : 832 |
Release | : 1998 |
Genre | : Corporations |
ISBN | : |
Download The Taxation of Companies in Europe Book in PDF, ePub and Kindle