Other Income Under Tax Treaties

Author: Alexander Bosman
Publisher: Kluwer Law International
ISBN: 9789041166104
Size: 71.20 MB
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Bilateral tax treaties are often, to a greater or lesser extent, based on the OECD Model Convention.

International Taxation

Author: Joseph Isenbergh
ISBN: 9781599414416
Size: 53.13 MB
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The Third Edition is divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties.

A Global Analysis Of Tax Treaty Disputes

Author: Eduardo Baistrocchi
Publisher: Cambridge University Press
ISBN: 1108150381
Size: 25.55 MB
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Article 6(1) of the former 1970 Belgium–Netherlands tax treaty provided that
income from immovable property may be taxed in the state in which such
property is situated. This provision is in line with the wording of Art. 6 of the 1963
OECD Model; compare A. Bosman, Other Income under Tax Treaties, Series on
International Taxation No. 55 (Amsterdam: Kluwer Law International, 2015), p.
180. 78 Compare HR 4 April 1990, BNB 1990/156, involving a member of the
Dutch military ...

Multilateral Tax Treaties

Author: Michael Lang
Publisher: Kluwer Law International
ISBN: 9041107045
Size: 79.43 MB
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The advantages and disadvantages of multilateral tax treaties have been debated for many years. While some multilateral tax treaties have been concluded at regional levels, the concept has yet to gain wide acceptance.

International Tax Law

Publisher: Kluwer Law International
ISBN: 9041123903
Size: 16.50 MB
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in the other Contracting State.71 The term beneficial owner, which is not defined
in the Model Convention,72 is not to be construed by reference to domestic laws
of the State applying the treaty. ... Ownership–Decision of the Netherlands
Supreme Court of 6 Apr. 1994, n. 28638”, in Eur. Tax., 1994, p. 469 et seq.; Ward,
“Abuse of Tax Treaties”, in Albert and Van Raad (eds.), Essays on International
Taxation, London-The Hague-Boston, 1993 (Series on International Taxation, no.

International Taxation Of Low Tax Transactions 2009 High Tax Jurisdictions

Author: Dennis Campbell
Publisher: Lulu.com
ISBN: 0557092205
Size: 39.67 MB
Format: PDF
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Under the income tax treaty between Japan and Germany, income derived by a
silent partner (Stiller Gesellschafter) is specifically included in the definition of
dividend income.55 The treaty has a special exception concerning the income
derived by a ... In this example, Country T has an income tax treaty with Japan
under which a provision known as the 'other income' clause allows only the
country of residence to tax 'other income' which is not covered by any of the other
articles of the ...

Introduction To United States International Taxation

Author: Paul R. McDaniel
Publisher: Kluwer Law International
ISBN: 9041123601
Size: 25.42 MB
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The 2005 edition of this well-known reference work for the tax community provides an introduction to the application of the United States international taxation system to taxpayers investing or transacting business in the US and other ...

International Taxation In A Nutshell

Author: Richard Doernberg
Publisher: West Academic
ISBN: 1634604350
Size: 28.11 MB
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For example, a contracting state is not free under its domestic law to tax
guarantee fees paid by a U.S. subsidiary to its foreign parent corporation for a
parent guarantee that helps the U.S. subsidiary secure a beneficial bank loan. It
should be noted, however, that some U.S. treaties (e.g., the treaty with Canada)
do permit source state taxation of Other Income. Under those treaties, the United
States would be able to collect a 30 percent withholding tax under its view that
such guarantee ...

Interpretation Of Tax Treaties Under International Law

Author: F. A. Engelen
Publisher: IBFD
ISBN: 9076078726
Size: 34.59 MB
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3-67; D.A. Ward, Principles to be Applied in Interpreting Tax Treaties, 34 IBFD
Bulletin 12, 1980, pp. 545-551; ALI, Federal Income Tax Project – International
Aspects of United States Income Taxation II, 1937, pp. 25-62; C. van Raad,
International Coordination of Tax Treaty Interpretation and Application, in: P.
Kirchhof, et al.(eds.), International and Comparative Taxation, Essays in Honour
of Klaus Vogel, 26 Series on International Taxation, Kluwer Law International,
The Hague etc., ...