U.S. Tax Treaties
Author: United States. Internal Revenue Service
Publisher:
Published: 1990
Total Pages: 28
ISBN-13:
DOWNLOAD EBOOKPosts
Using Treaties and Holding Companies for Latin American Tax Planning
Author: Amanda D. Johnson
Publisher: WorldTrade Executive, Inc.
Published: 2005
Total Pages: 170
ISBN-13: 9781893323704
DOWNLOAD EBOOKCollection of articles providing an insight in the current status of tax treaties in Latin American and Caribbean countries, and dealing with holding companies and technical assistance, royalty and service payments.
Interpretation and Application of Tax Treaties in North America
Author: Juan Angel Becerra
Publisher: IBFD
Published: 2007
Total Pages: 299
ISBN-13: 9087220197
DOWNLOAD EBOOKThis book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
International Tax Policy and Double Tax Treaties
Author: Kevin Holmes
Publisher: IBFD
Published: 2007
Total Pages: 433
ISBN-13: 9087220235
DOWNLOAD EBOOKExplains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Tax Planning With Double Tax Treaties
Author: L Hadnum
Publisher:
Published: 2021-05-24
Total Pages: 132
ISBN-13:
DOWNLOAD EBOOKThis bookcontains detailed information on how you can use the terms of the UK's double tax treaties to reduce your UK tax liability. Subjects covered include: Everything you need to know about tax treaty residence Double tax treaties and beneficial ownership - why it ́s so important How the new digital permanent establishments rules in India, Israel and other jurisdictions apply in 2021 and how double tax treaties impact on these rules Using a double tax treaty to provide services in the UK tax efficiently Using double tax treaties to work in the UK free of income tax Taking advantage of double tax treaties to reduce UK withholding tax How the new double tax treaty passport scheme works UK tax planning for ebook and other copyright royalties Tax planning with the EU interest & royalties directive Income tax on UK dividends for non UK residents How pensions are taxed when you're overseas How to claim double tax relief on UK pensions received overseas How a UK company can escape UK tax by using double tax treaties Reducing inheritance tax with an estate tax treaty Non-Doms: Tax treatment under double tax treaties 2017 changes to non-doms and the impact on tax treaties Non-Doms: How to claim the remittance basis and still benefit from the UK personal allowance3 Non-Doms: Using estate tax treaties to avoid the deemed domicile rules Review of the UK-US estate tax treaty Can you use the CGT article in a double tax treaty to avoid CGT? Tax planning with the new UK-China double tax treaty Tax planning with the new UK-Hong Kong double tax treaty What a teleworker needs to know about tax treaties Using a double tax treaty to provide services in the UK tax efficiently Plus lots more...
How to Use Double Tax Treaties in Tax Planning
Author: David Flux
Publisher:
Published: 1984
Total Pages:
ISBN-13:
DOWNLOAD EBOOKTax Planning with Double Tax Treaties
Author: Lee Hadnum
Publisher: Createspace Independent Pub
Published: 2015-03-04
Total Pages: 130
ISBN-13: 9781505628722
DOWNLOAD EBOOKThis guide contains detailed information on how you can use the terms of the UK's double tax treaties to reduce your UK tax liability.Subjects covered include: Everything you need to know about tax treaty residence Double tax treaties and beneficial ownership - why it´s so important Using a double tax treaty to provide services in the UK tax efficiently Using double tax treaties to work in the UK free of income tax Taking advantage of double tax treaties to reduce UK withholding tax How the new double tax treaty passport scheme works 2014 and 2015 tax changes UK tax planning for ebook and other copyright royalties Tax planning with the EU interest & royalties directive Income tax on UK dividends for non UK residents How pensions are taxed when you're overseas How to claim double tax relief on UK pensions received overseas How a UK company can escape UK tax by using double tax treaties Reducing inheritance tax with an estate tax treaty Non-Doms: Tax treatment under double tax treaties Non-Doms: How to claim the remittance basis and still benefit from the UK personal allowance3 Non-Doms: Using estate tax treaties to avoid the deemed domicile rules Review of the UK-US estate tax treaty Can you use the CGT article in a double tax treaty to avoid CGT? Tax planning with the new UK-China double tax treaty Tax planning with the new UK-Hong Kong double tax treaty How large multinationals use tax treaties to reduce their tax liabilities Plus lots more...
Tax Treaties: Building Bridges between Law and Economics
Author:
Publisher: IBFD
Published: 2010
Total Pages: 679
ISBN-13: 9087221185
DOWNLOAD EBOOKIn this book experts from the field of economics take a different view of tax treaty issues than experts from the field of law. In order to encourage the much needed communication between these two groups, a cross-disciplinary conference was held to discuss selected tax treaty issues from both a legal and economic perspective. Twenty-five conference papers on eight topics were prepared by lawyers and economists. The papers on legal issues were presented and discussed by economists, and vice versa. The interdisciplinary focus of the conference not only allowed an exchange of knowledge between two groups who think differently about similar issues, but also made it possible to better grasp the impact of the thinking of one group on the areas of interest to the other group. The outcome of the conference is reflected in this book. By showing the legal and the economic approaches to an issue, this book improves the general understanding of the two disciplines and demonstrates how the decisions in one discipline may influence the other discipline and its concepts. Twenty-two contributions are included, written by the most distinguished academics, practitioners and representatives of several international tax administrations and both tax and economic institutions.
Hybrid Entities in Tax Treaty Law
Author: Sriram Govind
Publisher: Linde Verlag GmbH
Published: 2020-09-03
Total Pages: 696
ISBN-13: 3709410754
DOWNLOAD EBOOKTax treaty law and EU tax law in connection with hybrid entities Hybrid entities have traditionally been used as an avenue for international tax planning, and extending benefits under tax treaties to such entities has been a source of controversy for many years now. Although the OECD Partnership Report provided solid policy footing on this issue, there was still no common legal basis that countries could rely on for such positions. The increasing focus of countries towards the curbing of tax avoidance and abuse involving hybrid mismatch arrangements culminated in a specific action plan in the BEPS Project being dedicated to the design of domestic rules and the development of treaty provisions that would neutralize the tax effects of such arrangements. This volume provides an in-depth analysis of various aspects of this topic. It is divided into two parts – the first dealing exclusively with tax treaty issues arising in connection with hybrid entities and the second dealing with EU tax law issues surrounding hybrid entities. The former part comprises chapters analysing how tax treaties have historically dealt with this issue with a focus on domestic court jurisprudence, the positions in the OECD and the UN Model Conventions, the developments that have come about owing to the BEPS Project, and the impact of several existing measures, regimes, and vehicles on these tax treaty provisions. The latter part comprises chapters on how hybrid entities are dealt with under primary EU law, under various secondary law directives including the newly enacted Anti-Tax Avoidance Directives, and an analysis of policy solutions offered in this direction.
Schwarz on Tax Treaties
Author: Jonathan Schwarz
Publisher: Kluwer Law International B.V.
Published: 2021-09-28
Total Pages: 870
ISBN-13: 9403526319
DOWNLOAD EBOOKSchwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
