Tax Treaties And Domestic Law PDF Download
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Author | : Guglielmo Maisto |
Publisher | : IBFD |
Total Pages | : 433 |
Release | : 2006 |
Genre | : Double taxation |
ISBN | : 9076078920 |
Download Tax Treaties and Domestic Law Book in PDF, ePub and Kindle
This book analyses the relationships between tax treaties and domestic law from a constitutional and an international point of view, and how they can be improved in the fields of treaty override, treaty residence and anti-abuse measures. It also shows how the issues raised by these relationships are resolved by tax administrations and courts in selected European and non-European countries.
Author | : Guglielmo Maisto |
Publisher | : IBFD |
Total Pages | : 435 |
Release | : 2007 |
Genre | : Courts |
ISBN | : 9087220138 |
Download Courts and Tax Treaty Law Book in PDF, ePub and Kindle
A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.
Author | : F. A. Engelen |
Publisher | : IBFD |
Total Pages | : 615 |
Release | : 2004 |
Genre | : Double taxation |
ISBN | : 9076078726 |
Download Interpretation of Tax Treaties under International Law Book in PDF, ePub and Kindle
This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).
Author | : Jonathan Schwarz |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 870 |
Release | : 2021-09-28 |
Genre | : Law |
ISBN | : 9403526319 |
Download Schwarz on Tax Treaties Book in PDF, ePub and Kindle
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Author | : Michael Lang |
Publisher | : |
Total Pages | : |
Release | : 2020 |
Genre | : |
ISBN | : 9789087226497 |
Download Tax Treaties and Procedural Law Book in PDF, ePub and Kindle
Author | : Juan Angel Becerra |
Publisher | : IBFD |
Total Pages | : 299 |
Release | : 2007 |
Genre | : Canada |
ISBN | : 9087220197 |
Download Interpretation and Application of Tax Treaties in North America Book in PDF, ePub and Kindle
This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. 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. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Author | : Georg Kofler |
Publisher | : Linde Verlag GmbH |
Total Pages | : 332 |
Release | : 2022-07-19 |
Genre | : Law |
ISBN | : 3709412331 |
Download Tax Treaty Case Law around the Globe 2021 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 thirty most important tax treaty cases that were decided around the world in 2020. 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 2021" 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 | : Kiyoshi Nakayama |
Publisher | : International Monetary Fund |
Total Pages | : 13 |
Release | : 2011-04-11 |
Genre | : Business & Economics |
ISBN | : 1475510195 |
Download Tax Policy Book in PDF, ePub and Kindle
Technical Notes and Manuals are produced by IMF departments to expand the dissemination of their technical assistance advice. These papers present general advice and guidance, drawn in part from unpublished technical assistance reports, to a broader audience. This new series was launched in August 2009.
Author | : Michael Lang |
Publisher | : |
Total Pages | : |
Release | : 2020 |
Genre | : |
ISBN | : 9789087226473 |
Download Tax Treaties and Procedural Law Book in PDF, ePub and Kindle
Author | : Richard L. Doernberg |
Publisher | : |
Total Pages | : 444 |
Release | : 1999 |
Genre | : Double taxation |
ISBN | : |
Download U.S. Income Tax Treaties Book in PDF, ePub and Kindle
Text originally prepared for a class. Includes course outline, assignments and supporting materials.