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International Taxation of Income from Services under Double Taxation Conventions: Development, Practice and Policy


ISBN13: 9789041195944
Published: February 2018
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £123.00



In stock.

International Taxation of Income from Services under Double Taxation Conventions: Development, Practice and Policy provides an overview of the taxation of income from services under double taxation conventions (DTCs) in major jurisdictions across the world.

Especially due to the precipitous growth of the digital economy and thus the increased internationalization of services provisions, the international taxation of services has become a dominant focus in international taxation. This multiple-award-winning book is a major contribution to the debate about tax reform.

It responds to the need for a comprehensive overview of the tax opportunities and risks relating to the provision of international services.

With a thorough analysis of the international taxation of income from services over the past two centuries, the author sheds new light on present tax policy debates and develops workable proposals for bringing brick-and-mortar DTCs into the digital reality.

What’s in this book:

With an abundance of case studies, treaty interpretations, appraisals of policy discussions, and practical solutions, the author examines every aspect of the subject, including the following:

  • the Model DTCs of the OECD, the United Nations, Germany, and the United States, their similarities and differences;
  • relationships among the multilateral instrument (MLI), the Model DTCs, and specific DTCs;
  • development of the provisions dealing with services in the DTCs;
  • how tax authorities and courts of different countries (e.g., the United States, Germany, Brazil, India, and China) apply DTC provisions on the taxation of international services;
  • opportunities and risks relating to different business practices, such as the subcontracting of services provisions, the hiring-out of labor, the secondment of employees, and the engagement of contract and toll manufacturers;
  • practical questions about the taxation of different distribution models – from fully fledged distributors to commissionaires;
  • challenges and proposals relating to the differentiation between various types of services under DTCs;
  • the permanent establishment concept;
  • to what extent the structure, purposes, and scope of DTCs differ from those of the General Agreement on Trade in Services (GATS);
  • how changes in the US Model DTC of 2016 affect international service provisions; and proposed changes to amending the OECD and UN Model DTCs.
Viable proposals to simplify DTC provisions dealing with service income and to align them with current challenges such as the digital economy and the increasing volume of remote services are offered, particularly in light of the likely impact of the Base Erosion and Profit Shifting (BEPS) package and its subsequent MLI.

How this will help you:

As the first in-depth analysis of the taxation of income from services vis-à-vis the MLI resulting from the OECD’s BEPS initiative, this book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers. This book thus serves as an indispensable tool for practitioners and interested academics who will benefit from the author’s skill in recognizing the ongoing role of taxation fundamentals in the major revolution currently underway.

Subjects:
Taxation
Contents:
Foreword
Acknowledgments
List of Abbreviations
CHAPTER 1
Introduction
CHAPTER 2
History of the Taxation of Income from Independent Services under Double Tax Conventions
CHAPTER 3
Taxation of Income from Entrepreneurial, Professional, and Technical Services under the OECD MC, UN MC, U.S. MC and German MC
CHAPTER 4
Do Legal or Economic Principles Provide an Answer as to the Division of the Right to Tax?
CHAPTER 5
Conclusions
Bibliography
Legal and Administrative Acts (In Chronological Order)
Administrative and Judicial Decisions (In Chronological Order)
Index

Series: Series on International Taxation

The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model ISBN 9789403542973
To be published May 2024
Kluwer Law International
£92.00
The Resolution of International Tax Disputes ISBN 9789403520889
To be published May 2024
Kluwer Law International
£75.00
Taxation of Derivatives and Cryptoassets 2nd ed ISBN 9789403523835
To be published April 2024
Kluwer Law International
£143.00
Double Non-taxation and the Use of Hybrid Entities 2nd ed ISBN 9789403546667
Published December 2023
Kluwer Law International
£144.00
Double Non-taxation and the Use of Hybrid Entities 2nd ed (eBook) ISBN 9789403546766
Published December 2023
Kluwer Law International
£144.00
(ePub)
Buy
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea (eBook) ISBN 9789403534176
Published November 2023
Kluwer Law International
£81.00
(ePub)
Buy
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea ISBN 9789403534077
Published November 2023
Kluwer Law International
£81.00
The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective (eBook) ISBN 9789403537627
Published August 2022
Kluwer Law International
£96.00
(ePub)
Buy
The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective ISBN 9789403537412
Published August 2022
Kluwer Law International
£96.00
£139.00
(ePub)
Buy
£139.00
Coordination and Cooperation: Tax Policy in the 21st Century ISBN 9789403537405
Published December 2021
Kluwer Law International
£128.00
Coordination and Cooperation: Tax Policy in the 21st Century (eBook) ISBN 9789403537603
Published December 2021
Kluwer Law International
£128.00
(ePub)
Buy
Exploring the Nexus Doctrine In International Tax Law (eBook) ISBN 9789403533643
Published May 2021
Kluwer Law International
£75.00
(ePub)
Buy
Regulation and Tax in Space (eBook) ISBN 9789403533940
Published May 2021
Kluwer Law International
£79.00
(ePub)
Buy
Exploring the Nexus Doctrine In International Tax Law ISBN 9789403533636
Published May 2021
Kluwer Law International
£75.00
Regulation and Tax in Space ISBN 9789403533933
Published May 2021
Kluwer Law International
£79.00
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed ISBN 9789403520612
Published July 2020
Kluwer Law International
£375.00
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed (eBook) ISBN 9789403520643
Published July 2020
Kluwer Law International
£375.00
(ePub)
Buy
International Taxation of Banking ISBN 9789403510941
Published February 2020
Kluwer Law International
£168.00
International Taxation of Banking (eBook) ISBN 9789403510958
Published February 2020
Kluwer Law International
£168.00
(ePub)
Buy
Tax Treaty Residence of Entities ISBN 9789403513010
Published November 2019
Kluwer Law International
£108.00
Hybrid Financial Instruments, Double Non-Taxation and Linking Rules ISBN 9789403510743
Published August 2019
Kluwer Law International
£130.00
Tax and the Digital Economy: Challenges and Proposals for Reform ISBN 9789403503615
Published May 2019
Kluwer Law International
£111.00
Taxation, Virtual Currency and Blockchain ISBN 9789403501031
Published December 2018
Kluwer Law International
£96.00
International Taxation of Energy Production and Distribution ISBN 9789041191014
Published May 2018
Kluwer Law International
£159.00
Out of print
£110.00
£110.00
Winning the Tax Wars: Tax Competition and Cooperation ISBN 9789041194602
Published December 2017
Kluwer Law International
£119.00
BRICS and International Tax Law ISBN 9789041194350
Published December 2017
Kluwer Law International
£149.00
Legal Interpretation of Tax Law 2nd ed ISBN 9789041184733
Published October 2017
Kluwer Law International
£149.00
Other Income under Tax Treaties ISBN 9789041166104
Published September 2015
Kluwer Law International
£241.00
General Anti - avoidance Rules for Major Developing Countries ISBN 9789041158390
Published October 2014
Kluwer Law International
£154.00
Proportionality and Fair Taxation ISBN 9789041158383
Published October 2014
Kluwer Law International
£167.00
Legal Interpretation of Tax Law ISBN 9789041149459
Published September 2014
Kluwer Law International
Out of print
Tax Reform in the 21st Century: A Volume in Memory of Richard Musgrave ISBN 9789041128294
Published July 2009
Kluwer Law International
£125.00
Interpretation Double Taxation Conventions: General Theory and Brazilian Perspective ISBN 9789041128225
Published February 2009
Kluwer Law International
£173.00
Sales Taxation ISBN 9789065443816
Published January 2002
Kluwer Law International
£212.00
Taxation of Foreign Direct Investment ISBN 9789041197412
Published August 1999
Kluwer Law International
£183.00
The Impact of State Sovereignty on Global Trade and International Taxation ISBN 9789041197030
Published May 1999
Kluwer Law International
£177.00
Multilateral Tax Treaties ISBN 9789041107046
Published June 1998
Kluwer Law International
£220.00
The Improper Use of Tax Treaties ISBN 9789041107374
Published June 1998
Kluwer Law International
£253.00
Taxing Corporate Profits in the EU ISBN 9789041107039
Published September 1997
Kluwer Law International
£279.00
Tax Treatment of Financial Instruments ISBN 9789065446664
Published June 1995
Kluwer Law International
£300.00
Issues in International Partnership ISBN 9789065445773
Published July 1993
Kluwer Law International
£233.00
Permanent Establishment: Erosion of a Tax Treaty Principle ISBN 9789065445940
Published October 1991
Kluwer Law International
Out of print
Tax Treaties and EC Law
ISBN 9789041106803
Published November 1990
Kluwer Law International
£295.00
International Juridical Double Taxation of Income ISBN 9789065444264
Published September 1989
Kluwer Law International
£281.00
Nondiscrimination in International Tax Law ISBN 9789065442666
Published July 1988
Kluwer Law International
£273.00
Tax Co-ordination in the European Community
ISBN 9789065442727
Published March 1987
Kluwer Law International
£388.00
International Studies in Taxation
ISBN 9789041196927
Published December 1968
Kluwer Law International
£253.00
Towards Corporate Tax Harmonization in the European Community
Adolfo J. Martin JimenezAssociate Professorr of Tax Law, University of Cadiz Law School, Jerez de la Frontera, Spain
ISBN 9789041196903
Published December 1968
Kluwer Law International
£296.00