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Vol 22 No 9 Sept/Oct 2017

Book of the Month

Cover of Corruption and Misuse of Public Office

Corruption and Misuse of Public Office

Price: £225.00

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Source Versus Residence: Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives

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ISBN13: 9789041127631
Published: September 2008
Publisher: Kluwer Law International
Country of Publication: Nethrlands
Format: Hardback
Price: £126.00



Despatched in 4 to 6 days.

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.

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Subjects:
Taxation

Series: Eucotax Series on European Taxation

Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
Price on Application
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
CCTB: 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
Limitation on Benefits Clauses in Double Taxation Conventions ISBN 9789041123701
Published December 2005
Kluwer Law International
Out of print
Tax Avoidance and EC Treaty Freedoms ISBN 9789041124029
Published December 2005
Kluwer Law International
£145.00
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
£245.00
£123.00
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