Principle of origin in tax conventions : a rethinking of models

Resource Information

The item Principle of origin in tax conventions : a rethinking of models 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 1 library branch.

Summary: This is an in-depth study that deals with mismatches in the structure of the current bilateral tax conventions on income and capital. These mismatches trigger international tax planning, generate (alleged) abuse of tax conventions, and impede tax neutrality. The principle of residence underlying the current tax conventions is identified as the main cause of these mismatches. The study discusses the OECD (2000), UN (1980), US (1996) and Netherlands (1987, with reference to the 1998 tax treaty policy update) model tax conventions on income and capital and the Preliminary Draft EC Multilateral Tax Convention on income and capital (1968). The models are individually discussed and compared with each other. The influence of EC law on double tax conventions is addressed separately. Case law and practical examples illustrate the flaws in the structure of current models. An alternative tax convention system based on the principle of origin is developed. According to the autor, an origin-based system will enhance the justification for allocation of tax jurisdiction, improve the efficient allocation of the production factors of labour and capital, reduce tax administration, fit e-commerce, improve the functioning of the EC's internal market, and enable developing states to reduce the gap in economic development with developed states

Work

Summary: This is an in-depth study that deals with mismatches in the structure of the current bilateral tax conventions on income and capital. These mismatches trigger international tax planning, generate (alleged) abuse of tax conventions, and impede tax neutrality. The principle of residence underlying the current tax conventions is identified as the main cause of these mismatches. The study discusses the OECD (2000), UN (1980), US (1996) and Netherlands (1987, with reference to the 1998 tax treaty policy update) model tax conventions on income and capital and the Preliminary Draft EC Multilateral Tax Convention on income and capital (1968). The models are individually discussed and compared with each other. The influence of EC law on double tax conventions is addressed separately. Case law and practical examples illustrate the flaws in the structure of current models. An alternative tax convention system based on the principle of origin is developed. According to the autor, an origin-based system will enhance the justification for allocation of tax jurisdiction, improve the efficient allocation of the production factors of labour and capital, reduce tax administration, fit e-commerce, improve the functioning of the EC's internal market, and enable developing states to reduce the gap in economic development with developed states

http://library.link/vocab/subjectName

Visit the Library

IBFD Library AmsterdamBorrow it

Rietlandpark 301, Amsterdam, 1019 DW, NL

52.3736660 4.9336932

Structured data from the Bibframe namespace is licensed under the Creative Commons Attribution 4.0 International License by International Bureau of Fiscal Documentation. Additional terms may apply to data associated with third party namespaces.