Tax treaty case law around the globe : 2017

Resource Information

The work Tax treaty case law around the globe : 2017 represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Tax treaty case law around the globe : 2017

Creator

• Tax treaty case law around the globe

Contributor

• Lang, M

Subject

• CFC
• MAP
• MFN
• OECD Model
• PE
• aircrew
• allocation of profits
• arm's length principle
• associated enterprises
• beneficial ownership
• business profits
• capital gains
• case law
• central management and control
• collection of tax
• cost contribution arrangement
• directors' fees
• dividend
• domestic tax law
• double taxation relief
• employment income
• entertainer
• income classification
• interest
• investment fund
• loan
• losses
• mutual assistance
• non-discrimination
• other income
• place of effective management
• remittance basis
• residence
• royalties
• sportsperson
• student
• tax authorities
• tax relief
• tax treaty
• technical services
• thin capitalization
• transfer pricing
• treaty abuse
• treaty override
• triangular cases
• worldwide income

Language

eng

Summary

This book provides a global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 37 most important tax treaty cases which were decided around the world in 2016. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. The book is divided into 8 parts: (1) personal and substantive scope (Art. 1, 2 and 4 OECD Model); (2) business profits and permanent establishments (Art. 5, 6, 7, 8 and 14 OECD Model; (3) associated enterprises (art. 9 OECD Model); (4) dividend and interest (Art. 10 and 11 OECD Model); (5) royalties and capital gains (Art. 12 and 13 OECD Model); (6) employment income (Art. 15, 18 and 19 OECD Model); (7) directors' fees, artistes and sportsmen, students and other income, methods to avoid double taxation (Art. 16, 17, 20, 21 and 23 OECD Model); (8) non-discrimination, mutual agreement and mutual assistance (Art. 24-27 OECD Model)

Geographic coverage

• International
• Asia
• European Union
• Europe
• Latin America
• Middle East
• North America
• South America

Index

no index present

Language note

English

Literary form

non fiction

Series statement

• Series on International Tax Law
• Schriftenreihe zum Internationalen Steuerrecht

Series volume

• Vol. 102
• Band 102