Credit and exemption under tax treaties in cases of differing income characterization

Resource Information

The work Credit and exemption under tax treaties in cases of differing income characterization 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, Continuing Resources.

Label

Credit and exemption under tax treaties in cases of differing income characterization

Creator

• Ward, D.A
• Raad, C. van
• Roberts, S.I
• Strobl, J
• Torrione, H
• Uckmar, V
• Van de Wiele, M
• Avery Jones, J.F
• De Broe, L
• Ellis, M.J
• Fontaneau, P
• Fontaneau, P-M
• Giuliani, F.M
• Goldberg, S.H
• Killius, J.K
• Lenz, R
• Magney, T.W
• Maisto, G
• Miyatake, T

Subject

• double taxation relief
• exemption method
• income classification
• tax treaty
• treaty interpretation
• credit method

Summary

Double taxation, or its opposite, can occur when the two parties to a tax treaty view a transaction differently. This article examines one of the ways this can occur: differences in the characterization of the income. It is quite clear that differing characterization of income does arise in practice and can lead to credit and exemption problems. The authors make an in-depth analysis of whether the residence state must give credit or exempt income when it characterizes the income differently from the source state

Citation source

In: European taxation. - Amsterdam. - Vol. 36 (1996), no. 4 ; p. 118-146

Geographic coverage

International

Language note

English