Individuals Income Under Double Taxation Conventions

Author: Daniel Vitor Bellan
Publisher: Kluwer Law International
ISBN: 9041132783
Format: PDF, ePub
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Tax conventions (or tax treaties) provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. Brazil has over two dozen such conventions in force. This number might seem small but the country will inevitably enter into more such treaties given its economic growth, foreign investments and economic globalization in general. Two highly practical aspects form the basis of the book's analysis: interpretation and qualification under international tax law; and Brazil's income tax on individuals. The author employs those starting points to tackle such thorny questions as: Is there coherence in the legal regime that is applicable to individuals' income in double taxation treaties? Is this "system" for individuals consistent? Is it in accordance with Brazilian constitutional principles? Professionals dealing with Brazil's tax regime will quickly find this work instructive, insightful and thought-provoking.

A Global Analysis of Tax Treaty Disputes

Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
ISBN: 1108150381
Format: PDF, ePub, Mobi
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This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.

CFC Legislation Tax Treaties and EC Law

Author: Michael Lang
Publisher: Kluwer Law International
ISBN: 9041122842
Format: PDF, Mobi
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CFC legislations are common to most OECD Member States. They are introduced to combat tax evasion by shifting profits to corporations situated in low tax jurisdictions. Without the introduction of CFC legislations, residents are free to set up corporations abroad to lower their tax burden. The reason is the shielding effect of non-resident corporations. Thus, especially high tax countries feel the need to deny the tax benefits of Controlled Foreign Corporations in low tax countries. 70 experts, including the National and General Reporters, convened for a joint conference on CFC legislations in Rust (Austria) from 3 ¿ 6 July 2003. 23 National Reports from nearly all EU countries as well as Australia, the Czech Republic, Estonia, Hungary, Israel, Lithuania, New Zealand and Norway deal with domestic CFC provisions and the influence of DTCs and EC law on CFC legislations. These National Reports and a summarizing General Report have been compiled and published in this volume.

Introduction to the Law of Double Taxation Conventions

Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709405459
Format: PDF, ePub, Docs
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Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of DTCs and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account: it deals with the new UN Model published in 2011, the latest version of article 7 of the OECD Model published in 2010, the on-going discussions relating to bank secrecy, the question of an effective exchange of information and the beneficial ownership concept. The latest versions of the OECD and UN Model Tax Conventions on Income and Capital as well as the OECD Model Convention with Respect to Estate, Inheritance and Gift Taxes are also included.

Taxation and Development A Comparative Study

Author: Karen B. Brown
Publisher: Springer
ISBN: 3319421573
Format: PDF, ePub, Mobi
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This volume examines the tax systems of some twenty countries to determine whether their tax laws are used to support growth and development across borders in lower-income and poor countries. Given the critical economic development needs of poorer countries and the importance of stability in these regions to the security of populations throughout the world, the use of a country’s tax laws to support investment in the developing world gains crucial significance. This book explores whether international standards promoting the fundamental values of the major tax systems of the world accommodate incentives for these nations. In addition, it analyzes the way in which adoption of principles by higher income nations to protect their own revenue bases has a spill-over effect, impairing the ability of developing countries to sustain their economies. Following an introduction that synthesizes worldwide trends, the volume contains separate chapters for a variety of countries detailing the underlying goals and values of each system and the way in which the decision to employ (or not employ) incentives accommodates those ends. The chapters include reports for: Australia, Belgium, Brazil, Croatia, Czech Republic, France, Hong Kong, Israel, Italy, Japan, the Maldives, the Netherlands, Poland, Portugal, South Africa, Uganda, United Kingdom, United States, and Venezuela. The volume memorializes the work of the General Reporter and National Reporters at the Taxation and Development session of the 19th Congress of the International Academy of Comparative Law held in July, 2014, in Vienna, Austria.

International Taxation of Income from Services Under Double Taxation Conventions

Author: Marta Castelon
Publisher:
ISBN: 9789041195944
Format: PDF, ePub, Mobi
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This book provides an overview of the taxation of income from services under double taxation conventions (DTCs) in major jurisdictions across the world. Especially due to the precipitous growth of the digital economy and thus the increased internationalization of services provisions, the international taxation of services has become a dominant focus in international taxation. This book is a major contribution to the debate about tax reform. It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services.00With a thorough analysis of the international taxation of income from services over the past two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality.