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Vol 23 No 2 Feb/March 2018

Book of the Month

Cover of The UK Supreme Court Yearbook Volume 8: 2016-2017 Legal Year

The UK Supreme Court Yearbook Volume 8: 2016-2017 Legal Year

Edited by: Daniel Clarry
Price: £120.00

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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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Series: Eucotax Series on European Taxation

Investment Fund Taxation: Domestic Law, EU Law, and Double Taxation Treaties ISBN 9789041196699
Published May 2018
Kluwer Law International
Price on Application
National Legal Presumptions and European Tax Law ISBN 9789041166135
Published February 2018
Kluwer Law International
Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
EU Citizenship and Direct Taxation ISBN 9789041185846
Published October 2017
Kluwer Law International
Transfer Pricing in the US: A Practical Guide ISBN 9789041191960
Published September 2017
Kluwer Law International
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed ISBN 9789041161352
Published September 2017
Kluwer Law International
The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
Published August 2016
Kluwer Law International
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
Tax Treaty Override ISBN 9789041154064
Published April 2014
Kluwer Law International
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
CCCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)
Edited by: Dennis Weber
ISBN 9789041138729
Published May 2012
Kluwer Law International
Intermediation of Insurance & Financial Services in European VAT ISBN 9789041137326
Published August 2011
Kluwer Law International
From Marks & Spencer to X Holding: The Future of Cross-Border Group Taxation ISBN 9789041133991
Published August 2011
Kluwer Law International
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future ISBN 9789041134035
Published December 2010
Kluwer Law International
Europe-China Tax Treaties ISBN 9789041132161
Published June 2010
Kluwer Law International
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
Tax Compliance Costs for Companies in an Enlarged European Community ISBN 9789041126665
Published May 2008
Kluwer Law International
ECJ-Recent Developments in Direct Taxation ISBN 9789041125095
Published March 2006
Kluwer Law International
Tax Avoidance and EC Treaty Freedoms ISBN 9789041124029
Published December 2005
Kluwer Law International
Limitation on Benefits Clauses in Double Taxation Conventions ISBN 9789041123701
Published December 2005
Kluwer Law International
Out of print
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
Tax Competition and EU Law
Carlo PintoResearch Associate, Department of Law, University of Amsterdam, Netherlands
ISBN 9789041199133
Published May 2003
Kluwer Law International
Settlement of Disputes in Tax Treaty Law ISBN 9789041199041
Published September 2002
Kluwer Law International
Tax Treaty Interpretation
Edited by: Michael Lang
ISBN 9789041198570
Published June 2002
Kluwer Law International
The Impact of Community Law on Tax Treaties: Issues and Solutions ISBN 9789041198600
Published February 2002
Kluwer Law International
The Compatibility of Anti-abuse Provisions in Tax Treaties with EC Law
ISBN 9789041196781
Published January 1999
Kluwer Law International
The Principle of Equality in European Taxation
ISBN 9789041196934
Published December 0002
Kluwer Law International