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The Resource Taxation of cross-border partnerships : double tax relief in hybrid and reverse hybrid situations

Taxation of cross-border partnerships : double tax relief in hybrid and reverse hybrid situations

Label
Taxation of cross-border partnerships : double tax relief in hybrid and reverse hybrid situations
Title
Taxation of cross-border partnerships : double tax relief in hybrid and reverse hybrid situations
Creator
Subject
Language
eng
Summary
International juridical double taxation constitutes a significant obstacle for the development of cross-border business activities. Even though this problem has been combated for decades, many difficulties are yet to be conquered. This book deals with problems regarding international double taxation in cross-border partnership structures. The heterogeneity of these business vehicles constitutes a challenging factor for countries' legislation on foreign-entity classification. As these regimes typically disregard the tax treatment of foreign entities for domestic tax purposes, cross-border partnerships often face the risk of being treated as taxable persons in one country but as transparent in another (so-called "asymmetrical situations"). International double taxation arising in asymmetrical situations fits badly into countries' regimes for double-tax relief. As a result, there is a considerable risk that international double taxation arising in asymmetrical situations is not appropriately relieved. In addition to identifying and analysing the reasons for these problems, this book presents potential approaches on how to deal with them de lege ferenda (what the law ought to be, as opposed to what the law is)
http://library.link/vocab/creatorName
Barenfeld, J
Geographic coverage
  • International
  • European Union
  • Europe
Index
no index present
Language note
English
Literary form
non fiction
Series statement
IBFD Doctoral Series
Series volume
Vol. 9
http://library.link/vocab/subjectName
  • partnership
  • hybrid entity
  • double taxation relief
Label
Taxation of cross-border partnerships : double tax relief in hybrid and reverse hybrid situations
Instantiates
Publication
Extent
xxii, 406 p.
Isbn
9789076078854
Label
Taxation of cross-border partnerships : double tax relief in hybrid and reverse hybrid situations
Publication
Extent
xxii, 406 p.
Isbn
9789076078854

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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      No. 1 The Boulevard, Mid Valley City Suite 22.03, Level 22, Centrepoint South Lingkaran Syed Putra, Kuala Lumpur, 59200, MY
      3.148008 101.712199
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