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Vol 22 No 7 July/August 2017

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A new edition has been published, the details can be seen here:
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed isbn 9789041161352

Limitation on Benefits Clauses in Double Taxation Conventions

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ISBN13: 9789041123701
ISBN: 9041123709
New Edition ISBN: 9789041161352
Published: December 2005
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £177.00



This is a Print On Demand Title.
The publisher will print a copy to fulfill your order. Books can take between 1 to 3 weeks. Looseleaf titles between 1 to 2 weeks.

In accordance with Article 22 of its 1996 Model Treaty, most double taxation conventions entered into by the United States contain a number of rules called limitation on benefits clauses, the purpose of which is to prevent the application of the benefits of the treaties to treaty shopping structures. Following the changes in the Commentaries on Article 1 of the OECD Model Tax Convention in 2003, a number of clauses similar to those provided in the United State s Model Treaty have been included.

In this study, the legal framework and application of these rules is analysed in depth, and particularly, taking into account those rules included in the double taxation conventions concluded between the United States and European Union member states. In this respect, the compatibility of these rules with European Community Law is also analysed in the last chapter.

This study is based on the author s doctoral thesis, which was awarded the prize for the best doctoral thesis on financial and tax law by the Spanish Instituto de Estudios Fiscales (Ministerio de Economia y Hacienda) in 2002.

ECUOTAX Series in European Taxation Vol 12

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Subjects:
Taxation
Contents:
Foreword.
Author's Note.
List of Abbreviations.
Introduction.
Taxation of Non-Residents and International Tax Planning Through DTC.
Subjective Scope of Double Taxation Conventions and Limitation on Benefits Clauses.
Legal Framework and Application of Limitation on Benefit Clauses.
Limitation on Benefit Clauses and EC Law.
Bibliography.
Index.;

Series: Eucotax Series on European Taxation

Corporate Tax Base in the Light of IAS/IFRS and EU Directive 2013/34: A Comparative Approach ISBN 9789041167453
Published July 2016
Kluwer Law International
£96.00
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
£96.00
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
£110.00
Tax Compliance Costs for Companies in an Enlarged European Community ISBN 9789041126665
Published May 2008
Kluwer Law International
£144.00
ECJ-Recent Developments in Direct Taxation ISBN 9789041125095
Published March 2006
Kluwer Law International
£116.00
Tax Avoidance and EC Treaty Freedoms ISBN 9789041124029
Published December 2005
Kluwer Law International
£145.00
£123.00
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
£245.00
Settlement of Disputes in Tax Treaty Law ISBN 9789041199041
Published September 2002
Kluwer Law International
£194.00
Tax Treaty Interpretation
Edited by: Michael Lang
ISBN 9789041198570
Published June 2002
Kluwer Law International
£162.00
The Impact of Community Law on Tax Treaties: Issues and Solutions ISBN 9789041198600
Published February 2002
Kluwer Law International
£175.00
The Compatibility of Anti-abuse Provisions in Tax Treaties with EC Law
ISBN 9789041196781
Published January 1999
Kluwer Law International
£171.00
The Principle of Equality in European Taxation
ISBN 9789041196934
Published December 0002
Kluwer Law International
£158.00