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Vol 22 No 11 Nov/Dec 2017

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The Law of Contract Damages

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This book is now Out of Print.
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: Out of print



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

National Legal Presumptions and European Tax Law ISBN 9789041166135
To be published December 2017
Kluwer Law International
£127.00
Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
£137.00
EU Citizenship and Direct Taxation ISBN 9789041185846
Published October 2017
Kluwer Law International
£114.00
Transfer Pricing in the US: A Practical Guide ISBN 9789041191960
Published September 2017
Kluwer Law International
£93.00
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed ISBN 9789041161352
Published September 2017
Kluwer Law International
£155.00
The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
Published August 2016
Kluwer Law International
£142.00
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
Tax Treaty Override ISBN 9789041154064
Published April 2014
Kluwer Law International
£104.00
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
£96.00
CCCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)
Edited by: Dennis Weber
ISBN 9789041138729
Published May 2012
Kluwer Law International
£112.00
Intermediation of Insurance & Financial Services in European VAT ISBN 9789041137326
Published August 2011
Kluwer Law International
£112.00
From Marks & Spencer to X Holding: The Future of Cross-Border Group Taxation ISBN 9789041133991
Published August 2011
Kluwer Law International
£104.00
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future ISBN 9789041134035
Published December 2010
Kluwer Law International
£104.00
Europe-China Tax Treaties ISBN 9789041132161
Published June 2010
Kluwer Law International
£104.00
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
£110.00
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
£108.00
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
Tax Competition and EU Law
Carlo PintoResearch Associate, Department of Law, University of Amsterdam, Netherlands
ISBN 9789041199133
Published May 2003
Kluwer Law International
£189.00
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