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Author : Association fiscale internationale. Congress (64 : 2010 : Roma)
Publisher : Unknown
Page : 906 pages
File Size : 53,8 Mb
Release : 2010
Category : Conflict of laws
ISBN : 9012383366
Author : Anonim
Publisher : Unknown
Page : 906 pages
File Size : 48,5 Mb
Release : 2010
Category : Inheritance and transfer tax
ISBN : OCLC:657494940
Author : Georg Kofler,Miguel Poiares Maduro,Pasquale Pistone
Publisher : IBFD
Page : 581 pages
File Size : 42,6 Mb
Release : 2011
Category : Human rights
ISBN : 9789087221119
Resumen del editor: "The increasing globalization and the restructuring of the European legal framework by the Treaty of Lisbon are important factors to suggest that the traditional separation of spheres between taxation and human rights should be revisited. This book examines the issues surrounding the impact of the Lisbon Treaty on the guarantee and enforcement of human rights in the area of EU (tax) law and explores the possible development and potential impact of human rights in the field of taxation in this age of global law."
Author : Xavier Oberson,Howard R. Hull
Publisher : IBFD
Page : 457 pages
File Size : 49,5 Mb
Release : 2011
Category : Double taxation
ISBN : 9789087220983
"Switzerland has recently witnessed an unprecedented level of tax treaty negotiations. Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty interpretation and application. These are considered extensively in this edition. As Switzerland has steadily aligned itself with international principles of international taxation, the self-imposed anti-abuse rules for the application of tax treaties have become less relevant. Nevertheless, Swiss courts have become more creative in determining where there is and where there is not treaty abuse. As a result, the 1962 Abuse Decree is making way for a more complex basket of anti-abuse rules and regulations"--Foreword (page vii).
Author : Dhruv Sanghavi
Publisher : Bloomsbury Publishing
Page : 530 pages
File Size : 52,9 Mb
Release : 2020-12-21
Category : Business & Economics
ISBN : 9789390176861
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
Author : Joanna Wheeler
Publisher : IBFD
Page : 449 pages
File Size : 48,7 Mb
Release : 2012
Category : Conflict of law
ISBN : 9789087221232
Le site d'IBFD indique : "This thesis reveals a fundamental flaw in the OECD Model, namely that it pays no attention to the person who is liable to tax in respect of the income for which treaty benefits are claimed. This "missing keystone" causes two major problems of interpretation. One problem arises if the contracting states attribute the income to different persons; the myriad ways in which such a conflict can occur is illustrated by an extensive comparison of the domestic law of the Netherlands and the United Kingdom in this respect. This missing keystone also causes a disconnection between the two principal conditions for treaty entitlement. The treaty residence of the claimant is based on a general liability to tax in a contracting state, whereas the distributive articles focus on the ownership of the income. Interpretation problems arise if domestic law imposes a tax liability on a person who is not the owner of the income, for example under anti-avoidance legislation or a corporate group regime. In order to eliminate this fundamental flaw, the thesis proposes a "new approach" in which the criterion for treaty entitlement is liability to tax on the income, backed up by substantial connections between the income and the treaty claimant and between the treaty claimant and the residence state. The new approach is tested in various situations, many of them decided cases, and proves to give appropriate policy results while respecting the tax sovereignty of states. The thesis includes a proposal for a re-draft of the OECD Model on this basis."
Author : Desiree Auer,Christina Dimitropoulou
Publisher : Linde Verlag GmbH
Page : 496 pages
File Size : 49,6 Mb
Release : 2021-09-21
Category : Law
ISBN : 9783709411605
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 : Paolo Scarioni
Publisher : EGEA spa
Page : 245 pages
File Size : 50,7 Mb
Release : 2013-01-18T00:00:00+01:00
Category : Law
ISBN : 9788823812598
The book outlines in the first part the main aspects of italian inheritance tax legislation and, namely, its territorial scope of application, the issues concerning the taxable estate – such as the valuation of assets, the deductibility of liabilities and the available exemptions – the applicable tax rates and, finally, the essential features of the procedural aspects. The analysis is carried out making a constant reference to the principles stated by the European Court of Justice that, since 2003 with the Barbier case, has been dealing with inheritance tax provisions paying attention to their consistency with the fundamental freedoms guaranteed by the eU treaty. In the second part of the book the analysis is shifted to the “state of the art” of the italian legislation regarding the taxation of trusts, focusing first on the recognition of trusts for income tax purposes and their tax residence and, subsequently, on the tax treatment of the income derived by the trust and of the distributions to the beneficiaries. At last, the application of the inheritance and gift tax is examined.
Author : United States. Congress. Senate. Committee on Finance. Subcommittee on International Trade
Publisher : Unknown
Page : 1384 pages
File Size : 43,7 Mb
Release : 1981
Category : Commercial policy
ISBN : UCAL:B5145643
Author : Anonim
Publisher : CCH Australia Limited
Page : 1945 pages
File Size : 53,8 Mb
Release : 2009
Category : Corporations
ISBN : 9781921485800
This book is a concise foreign tax reference tool for the practitioner who needs quick answers to basic corporate and individual tax questions.
Author : Anonim
Publisher : Unknown
Page : 128 pages
File Size : 54,6 Mb
Release : 1946
Category : International law
ISBN : CHI:44201623
Author : United States. Internal Revenue Service
Publisher : Unknown
Page : 28 pages
File Size : 41,5 Mb
Release : 1990
Category : Double taxation
ISBN : UFL:31262045595427
Author : United States. Congress. Senate. Committee on Foreign Relations. Subcommittee on International Organization and Disarmament Affairs
Publisher : Unknown
Page : 1406 pages
File Size : 42,9 Mb
Release : 1969
Category : Air defenses
ISBN : UCAL:B5148864
Author : David D. Whelehan
Publisher : Chancellor Publications
Page : 491 pages
File Size : 55,8 Mb
Release : 2002
Category : Insurance law, International
ISBN : 9781899217069
The editor has assembled a distinguished group of authorities on international life insurance to set out the key issues in this fast-changing area of international planning - and how to profit from the financial benefits it offers.
Author : United States. Congress. House. Committee on Ways and Means
Publisher : Unknown
Page : 984 pages
File Size : 46,8 Mb
Release : 1948
Category : Taxation
ISBN : UIUC:30112119787742