The Resource Characterisation and taxation of cross-border pipelines
Characterisation and taxation of cross-border pipelines
Resource Information
The item Characterisation and taxation of cross-border pipelines represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 2 library branches.
Resource Information
The item Characterisation and taxation of cross-border pipelines represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 2 library branches.
- Summary
- A cross-border pipeline is probably one of the most complex assets to be found, as it can cross several borders and boundaries or even be laid in transit states. Such a unique and complex asset creates very intricate tax issues. This study offers an in-depth discussion of the principal questions: How is a cross-border pipeline currently characterised according to the OECD Model Tax Treaty and its Commentaries? How is income from a cross-border pipeline allocated between the states involved and does the OECD's authorised "functional separate entity approach" apply to income from pipelines? The issues relating to the characterisation and taxation of cross-border pipelines are uncertain, unresolved, inconsistent and unpredictable. No common international approaches for the characterisation and taxation of pipelines exist. Moreover, the fact that the OECD Model Tax Convention and its Commentaries sometimes suggest different definitions of an income or asset without giving clear recommendations does not make the situation any clearer. This lack of uniformity potentially creates significant risks for governments and the petroleum industry. This book provides a comprehensive analysis of the issues related to the taxation of cross-border pipelines. It offers solutions to the various tax issues that a cross-border pipeline might raise. The book concludes by recommending changes to the OECD Model Tax Treaty and its Commentaries to reduce uncertainty, avoid double taxation or less than a single taxation, and establish a more common international approach for the characterisation and taxation of cross-border pipelines and their allocation
- Language
- eng
- Label
- Characterisation and taxation of cross-border pipelines
- Title
- Characterisation and taxation of cross-border pipelines
- Language
- eng
- Summary
- A cross-border pipeline is probably one of the most complex assets to be found, as it can cross several borders and boundaries or even be laid in transit states. Such a unique and complex asset creates very intricate tax issues. This study offers an in-depth discussion of the principal questions: How is a cross-border pipeline currently characterised according to the OECD Model Tax Treaty and its Commentaries? How is income from a cross-border pipeline allocated between the states involved and does the OECD's authorised "functional separate entity approach" apply to income from pipelines? The issues relating to the characterisation and taxation of cross-border pipelines are uncertain, unresolved, inconsistent and unpredictable. No common international approaches for the characterisation and taxation of pipelines exist. Moreover, the fact that the OECD Model Tax Convention and its Commentaries sometimes suggest different definitions of an income or asset without giving clear recommendations does not make the situation any clearer. This lack of uniformity potentially creates significant risks for governments and the petroleum industry. This book provides a comprehensive analysis of the issues related to the taxation of cross-border pipelines. It offers solutions to the various tax issues that a cross-border pipeline might raise. The book concludes by recommending changes to the OECD Model Tax Treaty and its Commentaries to reduce uncertainty, avoid double taxation or less than a single taxation, and establish a more common international approach for the characterisation and taxation of cross-border pipelines and their allocation
- http://library.link/vocab/creatorName
- Olsen, K
- Geographic coverage
- International
- Index
- no index present
- Language note
- English
- Literary form
- non fiction
- http://library.link/vocab/subjectName
-
- OECD Model
- natural resources
- mining industry
- PE
- preparatory or auxiliary activities
- immovable property
- passive income
- other income
- income classification
- allocation of income
- international taxation
- avoidance of double taxation
- tax treaty
- Label
- Characterisation and taxation of cross-border pipelines
- Extent
- xviii, 265 p.
- Isbn
- 9789087221317
- Isbn Type
- (print)
- Label
- Characterisation and taxation of cross-border pipelines
- Extent
- xviii, 265 p.
- Isbn
- 9789087221317
- Isbn Type
- (print)
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Characterisation-and-taxation-of-cross-border/ZRqRRQZ9XTU/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Characterisation-and-taxation-of-cross-border/ZRqRRQZ9XTU/">Characterisation and taxation of cross-border pipelines</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Characterisation-and-taxation-of-cross-border/ZRqRRQZ9XTU/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Characterisation-and-taxation-of-cross-border/ZRqRRQZ9XTU/">Characterisation and taxation of cross-border pipelines</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
