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Source Versus Residence: Problems Arising From the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives (Eucotax Series on European Taxation) epub download

by Michael Lang


Books and Looseleafs on Foreign Comparative and International Tax Law. foreign and international tax law resources.

Books and Looseleafs on Foreign Comparative and International Tax Law.

Source Versus Residence book. The source rules for income taxation are determined by Articles 6 through 21 of the OECD Model Convention. These rules are the product of a rather long history and it seems difficult to justify the scope of some in todayand world. Courts, tax administrators, and practitioners are confronted with a growing number of interpretation and application problems.

2 EUCOTAX Series on European Tax VOLUME 21 Integration . 3 ation VOLUME 2O Source versus Residence Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible.

2 EUCOTAX Series on European Tax VOLUME 21 Integration Approaches to Group Taxation in the European Internal Market by Ioanna Mitroyanni Group taxation normally deals with tax liability in the context of a single jurisdiction. In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well. 3 ation VOLUME 2O Source versus Residence Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives by Michael Lang One of the major objectives of tax treaties has been the avoidance of international double taxation.

Worldwide income taxation in the country of residence is a legal dogma of international taxation. Tax Law: International & Comparative Tax eJournal. We question this dogma from the perspective of relations betwe. 32 Pages Posted: 12 Feb 2013.

Eucotax series on European taxation, 1566-0737 ; v. 20. General Note: Papers from the conference titled "Source verses residence: the allocation of taxing rights in. .Double taxation Treaties Congresses Taxing power

Eucotax series on European taxation, 1566-0737 ; v. General Note: Papers from the conference titled "Source verses residence: the allocation of taxing rights in tax treaty law problems arising from the existing tax treaty provisions and possible alternatives" held at the Vienna University of Economics and Business Administration from 8-10 November 2007. General Note: "EUCOTAX. General Note: At head of title: Kluwer Law International. Double taxation Treaties Congresses Taxing power.

The OECD Model Tax Treaty, other model conventions, and the bilateral treaties drafted in accordance with .

The OECD Model Tax Treaty, other model conventions, and the bilateral treaties drafted in accordance with these models, allocate the taxing rights between the state of source and the state of residence. These rules are the product of a rather long history and it seems difficult to justify the scope of some in today’s world. 9789041127631 Source versus Residence: Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives.

EUCOTAX Series on European Taxation, 20. Alphen aan den Rijn, The Netherlands: Kluwer Law International, 2008. Pottow "The Myth (and Realities) of Forum Shopping in Transnational Insolvency. J. Int'l L. 32, no. 3 (2007): 785-817.

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One of the major objectives of tax treaties has been the avoidance of international double taxation. This is generally accomplished through the agreement of each country to limit, in specified situations set out in double tax treaties, its right to tax income earned from its territory by residents of another country.

The OECD Model Tax Treaty, other model conventions, and the bilateral treaties drafted in accordance with these models, allocate the taxing rights between the state of source and the state of residence. The source rules for income taxation are determined by Articles 6 through 21 of the OECD Model Convention. These rules are the product of a rather long history and it seems difficult to justify the scope of some in today’s world. Courts, tax administrators, and practitioners are confronted with a growing number of interpretation and application problems. In a globalized world with ever-increasing cross-border streams of income such problems command more and more attention.

This book is designed to analyze the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The distinguished contributors to the work examine the justification for these rules - as well as their scope – and highlight the most relevant interpretation and attendant application problems. In addition they’ll suggest how such rules should be modified and examine possible alternatives.

Source Versus Residence: Problems Arising From the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives (Eucotax Series on European Taxation) epub download

ISBN13: 978-9041127631

ISBN: 9041127631

Author: Michael Lang

Category: Other

Subcategory: Social Sciences

Language: English

Publisher: Kluwer Law International (September 11, 2008)

Pages: 388 pages

ePUB size: 1310 kb

FB2 size: 1100 kb

Rating: 4.2

Votes: 527

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