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Vol 21 No 9 Sept/Oct 2016

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Goode on Commercial Law

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The 2010 OECD Updates: Model Tax Convention & Transfer Pricing Guidelines – A Critical Review

ISBN13: 9789041138125
Published: September 2011
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Paperback
Price: £104.00

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Virtually all international taxation provisions ultimately stem from two fundamental sources, both originating at the OECD: The Model Tax Convention (on which more than 3,000 bilateral tax treaties are based), and the Transfer Pricing Guidelines.

During 2010, major revisions were made to both. This is the first publication to describe and analyse these amendments in depth. From a variety of perspectives, thirteen experts – lawyers, tax directors, representatives of the OECD and of tax administrations, and academics – discuss the updates and the issues that may arise regarding their interpretation and application.

The significant changes covered include:

  • application of tax treaties to collective investment vehicles;
  • application of tax treaties to state-owned entities, including sovereign wealth funds;
  • issues regarding short-term cross-border employment income;
  • application of tax treaties to international telecommunication operations;
  • selection of the most appropriate transfer pricing method to the circumstances of the case;
  • the transfer pricing aspects of business restructurings;
  • how to apply transactional profit methods; and
  • how to perform a comparability analysis.
This unique book provides an expert analysis of current, important topics in international taxation and transfer pricing. As such, it is a welcome and valuable resource for tax lawyers and consultants, corporate tax advisers, government officials and others involved in the international tax law market, as well as for academics and researchers in the field.

Preface. Part I Introduction.
Chapter 1 The 2010OECD MC Amendments and the Revised TP Guidelines: An Overview Stef van Weeghel & Jan Gooijer Part II The new Article 7 of the OECD MC: Attribution of Profits to PE.
Chapter 2 Article 7 – New OEVD Rules for Attributing Profit to Permanent Establishments Mary Bennett.
Chapter 3 The 2010 Eliminination of Article 7-3 (1963): Rise and Fall of an Article Hans Pijl.
Chapter 4 Attribution of Profits to PE: A Business Perspective Johan Muller. Part III Tax Treaty Entitlement of CIVs.
Chapter 5 Charaterization and Tax Treaty Issues of Collective Investment Vehicles: A Review of the OECD Report and the 2010 Amendments to the Model Tax Convention Bruna da Silva.
Chapter 6 Suggested Treaty Benefits Approaches for Collective Investment Vehicles ( CIVs) and Its Investors under the OECD MTC 2010 Update Hein Vermeulen.
Chapter 7 The 2010 CIV-Report: A Comparison with the 1999 Partnership Report Ton Stevens. Part IV Income from Employment.
Chapter 8 Updates to the Commentary on Article 15 of the OECD Model – Thoughts on the Interpretation of the Term ‘employer’ for Treaty Purposes Walter Andreoni.
Chapter 9 Some Selected Interpretation and Qualification Issues with Respect to Article 15(2)(b) and (c) of the OECD Model Frank P.G. Pötgens. Part V The Revised Transfer Pricing Guidelines.
Chapter 10 The 2010 update to the OECD Transfer Pricing Guidelines Caroline Silberztein.
Chapter 11 Chapters I and III of the 2010 OECD Guidelines: Capita Selecta Antonio Russo.
Chapter 12 OECD Revision of Chapters I-III and IX of the Transfer Pricing Guidelines: Some Comments on Hierarchy of Methods and Re-characterization of Actual Transactions Undertaken Guglielmo Maisto. Part VI Sovereign Wealth Funds.
Chapter 13 How to Treat(y) Sovereign Wealth Funds? The Application of Tax Treaties to State-owned Entities, including Sovereign Wealth Funds

Series: International Taxation

Customs Valuation and Transfer Pricing 2nd ed ISBN 9789041161345
To be published March 2017
Kluwer Law International
Taxation and Migration ISBN 9789041161369
Published October 2015
Kluwer Law International
Taxation of Derivatives ISBN 9789041159779
Published August 2015
Kluwer Law International
The VAT/GST Treatment of Public Bodies ISBN 9789041146632
Published January 2013
Kluwer Law International
Science, Technology and Taxation ISBN 9789041131256
Published July 2012
Kluwer Law International
Immovable Property under VAT: A Comparative Global Analysis ISBN 9789041131263
Published May 2011
Kluwer Law International
Transfer Pricing and the Arm's Length Principle in International Tax Law ISBN 9789041132703
Published September 2010
Kluwer Law International
The International Tax Law Concept of Dividend 2nd ed ISBN 9789041132062
Published August 2010
Kluwer Law International
Systems of General Sales Taxation: Theory, Policy and Practice ISBN 9789041128324
Published August 2009
Kluwer Law International
Taxpayers Rights: Theory, Origin and Implementation ISBN 9789041126504
Published September 2007
Kluwer Law International
Tax Treaty Law and EC Law ISBN 9789041126290
Published August 2007
Kluwer Law International
Tax Investment Incentives in Foreign Direct Investment ISBN 9789041122285
Published April 2004
Kluwer Law International
Customs Valuation and Transfer Pricing ISBN 9789041198884
Published December 2002
Kluwer Law International
International and Comparative Taxation: Essays in Honour of Klaus Vogel ISBN 9789041198419
Published September 2002
Kluwer Law International
The Dividend Concept in International Tax Law ISBN 9789041197658
Published January 2000
Kluwer Law International
Out of print