The Resource Amendments to article 8, OECD Model convention : opportunities for foreign container and shipping investment funds?

Amendments to article 8, OECD Model convention : opportunities for foreign container and shipping investment funds?

Label
Amendments to article 8, OECD Model convention : opportunities for foreign container and shipping investment funds?
Title
Amendments to article 8, OECD Model convention : opportunities for foreign container and shipping investment funds?
Creator
Subject
Language
eng
Summary
Foreign investment funds that invest in the container and shipping business are increasingly attracting German investors. The attractiveness of the investment is then in most cases based on the low taxation abroad, and the low-taxed income is often tax-exempt in Germany under art. 7 (business profits) of the respective double taxation treaty. Of course this only works if the investment company carries out a trade or business and falls within the scope of art. 7. But what about the other funds that do not fulfill these requirements? This article looks at the issues with reference to art. 8 of the new double taxation treaty between Germany and Singapore
Citation source
In: Tax planning international review. - London. - Vol. 33 (2006),
http://library.link/vocab/creatorName
Haase, F
Language note
English
http://library.link/vocab/subjectName
  • foreign investment
  • tax treaty
  • shipping
Label
Amendments to article 8, OECD Model convention : opportunities for foreign container and shipping investment funds?
Instantiates
Publication
Label
Amendments to article 8, OECD Model convention : opportunities for foreign container and shipping investment funds?
Publication

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