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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



Despatched in 4 to 6 days.

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.;