The Resource The relationship between controlled foreign corporation rules and tax sparing provisions in tax treaties : New Zealand case

The relationship between controlled foreign corporation rules and tax sparing provisions in tax treaties : New Zealand case

Label
The relationship between controlled foreign corporation rules and tax sparing provisions in tax treaties : New Zealand case
Title
The relationship between controlled foreign corporation rules and tax sparing provisions in tax treaties : New Zealand case
Creator
Subject
Language
eng
Summary
This article discusses a recent New Zealand Court of Appeal case involving the relationship between New Zealand's CFC rules and the tax sparing provision in the China-New Zealand Income Tax Treaty (1986). The Court rejected the taxpayer's claim on the basis of a narrow, literal interpretation of the elimination of double taxation article of the treaty
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 72 (2018), no. 7 ; p. 430-438
http://library.link/vocab/creatorName
Arnold, B.J
Geographic coverage
  • Pacific Islands
  • Asia
  • International
Language note
English
http://library.link/vocab/subjectName
  • OECD
  • CFC
  • tax sparing credit
  • tax treaty
  • double taxation
  • case law
Label
The relationship between controlled foreign corporation rules and tax sparing provisions in tax treaties : New Zealand case
Instantiates
Publication
Label
The relationship between controlled foreign corporation rules and tax sparing provisions in tax treaties : New Zealand case
Publication

Library Locations

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