The Resource Differences between residents and non-residents concerning progression

Differences between residents and non-residents concerning progression

Label
Differences between residents and non-residents concerning progression
Title
Differences between residents and non-residents concerning progression
Creator
Subject
Language
eng
Summary
This paper examines the measures to define objective similarity between a non-resident and a resident taxable person with respect to the taxation principles of the same tax jurisdiction and in the light of the non-discrimination principle. In addition, the overall tax burden of a person from the view of the source state and the residence state is defined using different methods for the avoidance of double taxation according to Arts. 23a and 23b OECD Model. In this respect the overriding effect of the EC Treaty freedom provisions over the bilateral tax treaty provisions are presented on the cases "Asscher" and "Gerritse". The question is raised whether a worldwide taxation of residents conflicts with the Community law and whether the optimal future system of elimination of double taxation in Europe is the full exemption method in the residence state, which will somehow exclude from the principle of worldwide taxation the Europe-wide taxation
Citation source
Bound in: Source versus residence in international tax law. - Wien : Linde, 2005 ; p. 419-441
http://library.link/vocab/creatorName
Babic, M
Geographic coverage
  • International
  • European Union
Language note
English
http://library.link/vocab/subjectName
  • progression
  • residence
  • non-discrimination
  • tax burden
  • double taxation relief
  • exemption method
  • credit method
Label
Differences between residents and non-residents concerning progression
Instantiates
Publication
Label
Differences between residents and non-residents concerning progression
Publication

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