Indian Double Taxation Agreements Tax Laws 5th Ed

Author : D P Mittal
Publisher : Unknown
Page : 3552 pages
File Size : 53,6 Mb
Release : 2008-09-01
Category : Double taxation
ISBN : 8184780214

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Indian Double Taxation Agreements & Tax Laws 5Th / Ed. by D P Mittal Pdf

A Comprehensive and authentic Commentary on Indian Double Taxation Agreements with the help of decisions of International & Indian Courts as well as Authority for Advance Rulings * A comprehensive & critical study of UN Model Convention * Comparative and critical analysis of OECD Model Convention * Doing business with or in India, including e-business * Genesis and development of Treaty Models * Supremacy of a Tax Treaty over the domestic laws * Interpretation of a Tax Treaty * Classification of Income * Scope and purpose of a Tax Treaty * Taxes covered by a Treaty * Explaining definitions and expressions used in a tax treaty such as 'Resident', 'Permanent establishment', and others including 'Transfer pricing', 'Arm's length transactions', 'Treaty Shopping', etc. * Explaining expressions used in domestic tax laws but not defined in tax treaties such as Income (Real Income, Fictional Income, Substance over form). Total Income, Business, Profession, Computation of Income, etc. * Computation of income and distributive rules relating to income from Business, Shipping Business, Associates Enterprises, Capital Gains, Investment Income (dividends, interest, and royalties), Income from activities (personal and impersonal, pensions, directors' fee, entertainment, athletes, sports), Remuneration to students, etc. * Non-discrimination * Mutual agreement procedure for resolving disputes * Methods of eliminating Double Taxation, including Tax Sparing * Test of Double Taxation Agreements and Compendium of Relevant Circulars * Compendium of Rulings of Authority of Advance Rulings

Author : D. P. Mittal
Publisher : Unknown
Page : 128 pages
File Size : 42,5 Mb
Release : 2001
Category : Double taxation
ISBN : 8174962743

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Taxmann's Indian Double Taxation Agreements & Tax Laws by D. P. Mittal Pdf

Author : Ekkehart Reimert,Alexander Rust
Publisher : Kluwer Law International B.V.
Page : 3112 pages
File Size : 54,6 Mb
Release : 2022-01-18
Category : Law
ISBN : 9789403512846

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Klaus Vogel on Double Taxation Conventions by Ekkehart Reimert,Alexander Rust Pdf

Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University

Author : Michael Lang
Publisher : Linde Verlag GmbH
Page : 266 pages
File Size : 52,6 Mb
Release : 2021-04-01
Category : Law
ISBN : 9783709408629

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Introduction to the Law of Double Taxation Conventions by Michael Lang Pdf

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 : Anonim
Publisher : Unknown
Page : 128 pages
File Size : 52,9 Mb
Release : 2015
Category : Electronic
ISBN : 9041160558

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Klaus Vogel on Double Taxation Conventions by Anonim Pdf

Author : Xavier Oberson,Howard R. Hull
Publisher : IBFD
Page : 457 pages
File Size : 55,7 Mb
Release : 2011
Category : Double taxation
ISBN : 9789087220983

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Switzerland in International Tax Law by Xavier Oberson,Howard R. Hull Pdf

"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 : Vern Krishna
Publisher : Unknown
Page : 746 pages
File Size : 49,6 Mb
Release : 2012
Category : Income tax
ISBN : 1552212351

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Income Tax Law by Vern Krishna Pdf

This book is a comprehensive, up-to-date treatise on income tax law in Canada. The book introduces students and practitioners to income tax law in its broadest dimensions. It addresses the subject matter based on principles, policy, and practice. The objective is to explain what the law is, why it is the way it is, and how it works (or does not).

Author : Anonim
Publisher : Unknown
Page : 52 pages
File Size : 54,8 Mb
Release : 1998
Category : Aliens
ISBN : MINN:30000005590827

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U.S. Tax Guide for Aliens by Anonim Pdf

Author : S.N.L Agarwala/prabhat Agarwal/usha Agarwal
Publisher : TAXMANN PUBLICATIONS PVT LTD
Page : 8 pages
File Size : 43,9 Mb
Release : 2003
Category : Electronic
ISBN : 9788174964922

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ASSESSMENT OF BUSINESS PROFITS by S.N.L Agarwala/prabhat Agarwal/usha Agarwal Pdf

A Comprehensive and Practical Guide on Assessment of Profits from Business * Emerging trends in assessment of profit. * Challenges to book profit. * Profitability ratios. * Additions and deductions. * Deemed profits and gains. * Export profit. * Presumptive income. * Protective assessment. * Assessment in search and seizure cases under the Block Assessment Scheme as well as under New Assessment Scheme. This book will help in developing skills for determination of profit that is charged to income-tax. It is useful for tax administrators, tax consultants and taxpayers as a handy reference book on the subject.

Author : Mr.Victor Thuronyi
Publisher : International Monetary Fund
Page : 534 pages
File Size : 54,7 Mb
Release : 1996-08-23
Category : Business & Economics
ISBN : 1557755876

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Tax Law Design and Drafting, Volume 1 by Mr.Victor Thuronyi Pdf

Edited by Victor Thuronyi, this book offers an introduction to a broad range of issues in comparative tax law and is based on comparative discussion of the tax laws of developed countries. It presents practical models and guidelines for drafting tax legislation that can be used by officials of developing and transition countries. Volume I covers general issues, some special topics, and major taxes other than income tax.

Author : Andrew Lymer,John Hasseldine
Publisher : Springer Science & Business Media
Page : 319 pages
File Size : 49,6 Mb
Release : 2012-12-06
Category : Business & Economics
ISBN : 9781461510710

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The International Taxation System by Andrew Lymer,John Hasseldine Pdf

International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.

Author : OECD
Publisher : OECD Publishing
Page : 216 pages
File Size : 42,6 Mb
Release : 2018-03-16
Category : Electronic
ISBN : 9789264293083

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OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Interim Report 2018 Inclusive Framework on BEPS by OECD Pdf

This interim report of the OECD/G20 Inclusive Framework on BEPS is a follow-up to the work delivered in 2015 under Action 1 of the BEPS Project on addressing the tax challenges of the digital economy.

Author : Anonim
Publisher : Bloomsbury Publishing
Page : 829 pages
File Size : 41,9 Mb
Release : 2015-01-01
Category : Law
ISBN : 9781780436777

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International Tax Handbook by Anonim Pdf

This truly indispensable book from Nexia International condenses the KEY rates, reliefs and tax facts from 80 regimes into one essential guide.It's an accessible and user-friendly first point of reference for accountants, tax advisers, policy-makers, investors looking at opportunities overseas and anyone considering living or working abroad.Each chapter covers a single jurisdiction and includes information on: - Legal Forms - Corporate Tax - Personal Tax - Withholding Taxes - Indirect TaxesEach country-specific chapter is organised and presented in the same format and style. The chapters are organised alphabetically by country which ensures readers can quickly find the information they need on a specific country. Written by Nexia members based in the relevant tax regime, The International Tax Handbook provides a concise overview of taxation in these regimes: Argentina, Australia, Austria, Bahrain, Belgium, Bolivia, Brazil, British Virgin Islands, Bulgaria, Cameroon, Canada, Channel Islands - Guernsey, Channel Islands - Jersey, Chile, China, Colombia, Costa Rica, Cyprus, Czech Republic, Denmark, Dominican Republic, Egypt, Estonia, Finland, France, Germany, Ghana, Gibraltar, Greece, Guatemala, Hong Kong SAR, Hungary, India, Iran, Ireland, Isle of Man, Israel, Italy, Japan, Kenya, Korea, Lebanon, Liechtenstein, Luxembourg, Malaysia, Malta, Mauritius, Mexico, Morocco, Namibia, The Netherlands, New Zealand, Nigeria, Oman (Sultanate of Oman), Pakistan, Panama, Paraguay, Peru, Poland, Portugal, Qatar, Romania, Russia, Saudi Arabia, Singapore, Slovak Republic, South Africa, Spain, Sri Lanka, Sweden, Switzerland, Taiwan, Tanzania, Thailand, Tunisia, Turkey, Ukraine, United Arab Emirates, United Kingdom, United States, Uruguay, Vietnam.Previous edition ISBN: 9781780431277

Author : Bimal N. Patel
Publisher : BRILL
Page : 596 pages
File Size : 55,8 Mb
Release : 2008-02-06
Category : Law
ISBN : 9789047430803

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India and International Law, Volume 2 by Bimal N. Patel Pdf

India and International Law, volume 2 examines India’s policy and practical approach to modern and emerging subjects such as energy, investment, sports, banking, biotechnology, taxation, water courses, feminism, air law and role of India in UN reforms. The most discussed interlinked issues of civilian nuclear energy and nuclear weapons are analysed in two separate chapters. This volume also examines legal challenges and offers possible solutions in the area of private international law, which hopefully would serve the purposes of relevant policy-makers, judiciary, common men and women and 2.5 million Non-Resident Indians (NRIs).India and International Law, volume 2 will enable the readers to realize the sheer magnitude of legal challenges faced by India, hence, one way forward is to consider some of the suggestions offered by the authors. It is hoped that these two volumes will provide a useful framework for similar studies and will remain a must source of consultation for those who are interested in India’s state practice on international law.

Author : Ajit Kumar Singh
Publisher : Kluwer Law International B.V.
Page : 234 pages
File Size : 44,5 Mb
Release : 2021-05-14
Category : Law
ISBN : 9789403533643

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Exploring the Nexus Doctrine In International Tax Law by Ajit Kumar Singh Pdf

In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.