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| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 2624 |
| Release | : 2019-04-25 |
| Genre | : |
| ISBN | : 9264306994 |
This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
| Author | : Juan Angel Becerra |
| Publisher | : IBFD |
| Total Pages | : 299 |
| Release | : 2007 |
| Genre | : Canada |
| ISBN | : 9087220197 |
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 | : Karl P Sauvant |
| Publisher | : Oxford University Press |
| Total Pages | : 795 |
| Release | : 2009-03-27 |
| Genre | : Law |
| ISBN | : 0199745188 |
Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.
| Author | : OECD |
| Publisher | : OECD Publishing |
| Total Pages | : 2289 |
| Release | : 2015-10-30 |
| Genre | : |
| ISBN | : 9264239081 |
This publication is the ninth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention on Income and on Capital as it read on 15 July 2014.
| Author | : Guglielmo Maisto |
| Publisher | : IBFD |
| Total Pages | : 433 |
| Release | : 2006 |
| Genre | : Double taxation |
| ISBN | : 9076078920 |
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 | : Eduardo Baistrocchi |
| Publisher | : Cambridge University Press |
| Total Pages | : 2216 |
| Release | : 2017-08-17 |
| Genre | : Law |
| ISBN | : 1108150381 |
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
| Author | : Reuven S. Avi-Yonah |
| Publisher | : Edward Elgar Publishing |
| Total Pages | : 214 |
| Release | : 2019 |
| Genre | : Double taxation |
| ISBN | : 1788978498 |
This Second Edition provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes. It includes new material on BEPS, the EU Anti Tax Avoidance Package, and the US Tax Cuts and Jobs Act.
| Author | : Carla De Pietro |
| Publisher | : Kluwer Law International |
| Total Pages | : 0 |
| Release | : 2014 |
| Genre | : Conflict of laws |
| ISBN | : 9789041154064 |
The term è^-treaty overrideè^-- has acquired a specific connotation for tax treaty purposes, which requires an in-depth analysis. There is a tendency for domestic legislation to be passed (or court cases decided) which may override provisions of tax treaties. Despite the many conflicts and uncertainties about what tax treaty override exactly is and the exact point in time when tax treaty override occurs, its implications have not until now been analysed in a systematic manner.
