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
Resource Information
The item Triangular cases: the application of bilateral income tax treaties in multilateral situations 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 Triangular cases: the application of bilateral income tax treaties in multilateral situations 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
- 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
- Language
- eng
- 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
- 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
- Extent
- xxii, 874 p.
- Isbn
- 9789087222307
- Isbn Type
- (print)
- Label
- Triangular cases: the application of bilateral income tax treaties in multilateral situations
- Extent
- xxii, 874 p.
- Isbn
- 9789087222307
- 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/Triangular-cases-the-application-of-bilateral/Upo0Q_VSEhE/" 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/Triangular-cases-the-application-of-bilateral/Upo0Q_VSEhE/">Triangular cases: the application of bilateral income tax treaties in multilateral situations</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/Triangular-cases-the-application-of-bilateral/Upo0Q_VSEhE/" 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/Triangular-cases-the-application-of-bilateral/Upo0Q_VSEhE/">Triangular cases: the application of bilateral income tax treaties in multilateral situations</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>
