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The Resource Structural issues in the income tax treaty network : towards a coherent framework

Structural issues in the income tax treaty network : towards a coherent framework

Label
Structural issues in the income tax treaty network : towards a coherent framework
Title
Structural issues in the income tax treaty network : towards a coherent framework
Creator
Subject
Language
eng
Summary
The dissertation analyses the interaction of various provisions of the 2014 OECD Model Convention also taking into account BEPS developments. Chapter 2 deals with the question whether article 1 OECD Model has a restrictive or prescriptive effect. Chapter 3 exhaustively deals with various issues pertaining to the interpretation of art 4, paragraphs 1 and 3. Chapter 4 deals with interaction of articles 6, 7 and 21. Chapter 5 deals with hybrid entities. Chapter 6 is a short overview of some residual issues including issues about dual source rules arising on account of different definitions of a PE. Chapter 7 provides an overview of recommended changes to the OECD Model. The book includes a comprehensive review of historical documents relating to the issues discussed
http://library.link/vocab/creatorName
Sanghavi, D
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
http://library.link/vocab/subjectName
  • OECD Model
  • tax treaty
  • residence principle of taxation
  • allocation of taxing rights
  • hybrid entity
  • situs rule
  • source of income
  • PE
  • history of taxation
  • international tax law
  • treaty interpretation
Label
Structural issues in the income tax treaty network : towards a coherent framework
Instantiates
Publication
Extent
xxvi, 355 p.
Isbn
9789402809725
Label
Structural issues in the income tax treaty network : towards a coherent framework
Publication
Extent
xxvi, 355 p.
Isbn
9789402809725

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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