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The Resource Triangular cases: the application of bilateral income tax treaties in multilateral situations

Triangular cases: the application of bilateral income tax treaties in multilateral situations

Label
Triangular cases: the application of bilateral income tax treaties in multilateral situations
Title
Triangular cases: the application of bilateral income tax treaties in multilateral situations
Creator
Subject
Language
eng
Summary
Bilateral income tax treaties do not always operate effectively in situations where more than two states are involved. These situations are known as "triangular cases" and they typically arise where a person who is resident in two states for tax purposes (a dual resident), or a person who is resident in one state and has a permanent establishment (PE) in another, has dealings with a resident of a third state. This thesis explores the issues presented by the application of bilateral tax treaties in PE triangular cases, dual resident triangular cases and reverse triangular cases. Key among these issues is the fact that the source state is not required to apply the conditions of the treaty between the PE state and the source state, even though the treaty between the residence state and the PE state will allocate the prior (and perhaps exclusive) taxing rights to the PE state. This book argues that this approach should be reconsidered. It argues that residence concepts do not always provide a strong foundation on which to base eligibility for treaty benefits, that the PE concept and, in particular, the attribution of income to the PE, represents a sufficiently strong connection to the PE state to support a treaty claim, and that treaty-shopping concerns can be sufficiently addressed. As part of this analysis, this book examines the most fundamental questions associated with tax treaties: when they should apply, how they should apply, and what all those familiar concepts really mean
http://library.link/vocab/creatorName
Fett, E
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
IBFD doctoral series
Series volume
vol. 29
http://library.link/vocab/subjectName
  • triangular cases
  • tax treaty
  • PE
  • residence
  • double taxation relief
  • non-discrimination
  • source principle of taxation
  • allocation of taxing rights
  • allocation of profits
  • treaty benefits
  • dual residence
Label
Triangular cases: the application of bilateral income tax treaties in multilateral situations
Instantiates
Publication
Extent
xxii, 874 p.
Isbn
9789087222314
Isbn Type
(eBook)
Label
Triangular cases: the application of bilateral income tax treaties in multilateral situations
Publication
Extent
xxii, 874 p.
Isbn
9789087222314
Isbn Type
(eBook)

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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