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Vol 22 No 7 July/August 2017

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Manual of Housing Law

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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

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Kluwer Law International
£93.00
The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
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Kluwer Law International
£142.00
Tax Treaty Override ISBN 9789041154064
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£104.00
CCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)
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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
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
£108.00
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