Individuals Income Under Double Taxation Conventions
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Author | : Michael Lang |
Publisher | : Linde Verlag GmbH |
Total Pages | : 266 |
Release | : 2021-04-01 |
Genre | : Law |
ISBN | : 3709408628 |
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 | : |
Publisher | : |
Total Pages | : 169 |
Release | : 1963 |
Genre | : |
ISBN | : 9789264073241 |
This 1963 report presents the articles on the avoidance of double taxation on income and capital, as agreed upon by the Fiscal Committee. Double taxation is the taxation of a single taxpayer with respect to the same subject matter over the same period in more than one country. This draft aims to inspire further conventions on the elimination of double taxation, a threat to trade and migration. The report includes commentaries on the articles, progress on the elimination of double taxation, and possible future developments.
Author | : Daniel Vitor Bellan |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 466 |
Release | : 2010-09-03 |
Genre | : Law |
ISBN | : 9041142398 |
Tax conventions (or tax treaties) provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. Brazil has over two dozen such conventions in force. This number might seem small but the country will inevitably enter into more such treaties given its economic growth, foreign investments and economic globalization in general. Two highly practical aspects form the basis of the book’s analysis: interpretation and qualification under international tax law; and Brazil’s income tax on individuals. The author employs those starting points to tackle such thorny questions as: Is there coherence in the legal regime that is applicable to individuals’ income in double taxation treaties? Is this “system” for individuals consistent? Is it in accordance with Brazilian constitutional principles? Professionals dealing with Brazil’s tax regime will quickly find this work instructive, insightful and thought-provoking.
Author | : |
Publisher | : |
Total Pages | : 323 |
Release | : 2008 |
Genre | : |
ISBN | : |
This study analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 658 |
Release | : 2017-12-18 |
Genre | : |
ISBN | : 9264287957 |
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
Author | : Richard L. Doernberg |
Publisher | : |
Total Pages | : 444 |
Release | : 1999 |
Genre | : Double taxation |
ISBN | : |
Text originally prepared for a class. Includes course outline, assignments and supporting materials.
Author | : Kevin Holmes |
Publisher | : IBFD |
Total Pages | : 433 |
Release | : 2007 |
Genre | : Double taxation |
ISBN | : 9087220235 |
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Author | : United States |
Publisher | : |
Total Pages | : 16 |
Release | : 1954 |
Genre | : Double taxation |
ISBN | : |
Author | : Mitchell Benedict Carroll |
Publisher | : |
Total Pages | : 36 |
Release | : 1928 |
Genre | : Double taxation |
ISBN | : |
Author | : Sunita Jogarajan |
Publisher | : Cambridge University Press |
Total Pages | : 356 |
Release | : 2018-05-10 |
Genre | : Law |
ISBN | : 1108383742 |
Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.