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The Resource International taxation of income from services under double taxation conventions : development, practice and policy

International taxation of income from services under double taxation conventions : development, practice and policy

Label
International taxation of income from services under double taxation conventions : development, practice and policy
Title
International taxation of income from services under double taxation conventions : development, practice and policy
Creator
Subject
Language
eng
Summary
The provision of international services has increased enormously, mainly due to the precipitous growth of the digital economy. Accordingly, the interpretation and application of double taxation conventions (DTCs) to income from services has become a dominant focus in the international taxation. This book provides a comprehensive overview of the tax opportunities and risks relating to the provision of international services. It also offers an in-depth analysis of the taxation of income from services vis-à-vis the multilateral instrument (MLI) resulting from the OECD's Base Erosion and Profit Shifting (BEPS) initiative. With the thorough analysis of the international taxation of income from services over the last two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality. The author examines every aspect of the subject, including the following: - the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences; - relationships among the MLI, the Model DTCs, and specific DTCs; - development of the provisions dealing with services in the DTCs; - how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services; - opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labour, the secondment of employees, and the engagement of contract and toll manufacturers; -practical questions about the taxation of different distribution models - from fully edged distributors to commissionaires; - challenges and proposals relating to the differentiation between various types of services under DTCs; - the permanent establishment concept; - to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS); - how changes in the US Model DTC of 2016 affect international service provisions; and - proposed changes to amending the OECD and UN Model DTCs. Viable proposals to simplify DTC provisions dealing with service income and align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the 'BEPS package' and its subsequent MLI
http://library.link/vocab/creatorName
Castelon, M. Oliveros
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
Series on international taxation
Series volume
63
http://library.link/vocab/subjectName
  • OECD Model
  • international tax law
  • income tax
  • services
  • tax treaty
  • MLI
  • BEPS Action Plan
  • PE
  • UN Model
  • US Model
  • case law
  • hiring-out of labour
  • secondment
  • contract manufacturing
  • commissionaire
  • GATS
  • digital economy
Label
International taxation of income from services under double taxation conventions : development, practice and policy
Instantiates
Publication
Extent
xxxii, 501 p.
Isbn
9789041195968
Isbn Type
(web-pdf)
Label
International taxation of income from services under double taxation conventions : development, practice and policy
Publication
Extent
xxxii, 501 p.
Isbn
9789041195968
Isbn Type
(web-pdf)

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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