Permanent Establishments

Author: Ekkehart Reimer
Publisher: Kluwer Law International
ISBN: 904113123X
Size: 70.92 MB
Format: PDF, Docs
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This publication will be shortly available online at: www.kluwerlawonline.com Permanent Establishment in Cross-Border Transactions: Law, Analysis and Compliance Strategies will consist of two parts: Part One ' PE: The Legal and Compliance ...

Taxation In A Global Digital Economy

Author: Ina Kerschner
Publisher: Linde Verlag GmbH
ISBN: 3709409055
Size: 17.84 MB
Format: PDF
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926 Rahul Batheja, Treaty Abuse and Permanent Establishments: Proposed
Changes to Article 5(3) and (4) of the OECD MC in: Daniel W. Blum/Markus
Seiler (eds.), Preventing Treaty Abuse (Vienna: Linde, 2016) p. 387. 927
Ekkehart Reimer/Stefan Schmid/Marianne Orell, Permanent establishments: A
domestic taxation, bilateral tax treaty and OECD perspective (Den Hague: Kluwer
Law International, 2014) p. 86 et seq.; Michael Lang/Pasquale Pistone/Alexander
Rust/Josef ...

Preventing Treaty Abuse

Author: Daniel Blum
Publisher: Linde Verlag GmbH
ISBN: 3709408385
Size: 48.90 MB
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1572 OECD, Report on Action 7: Preventing the Artificial Avoidance of
Permanent Establishment Status, Section B, page 39, paragraph 14. 1573 OECD
, Report on Action 7: Preventing the Artificial Avoidance of Permanent
Establishment Status, Section B, page 39, paragraph 15. 1574 1575 1576 1577
1578 1579 1580 See for example, E. Reimer in: Permanent Establishments: A
Domestic Taxation, Bilateral Tax Treaty and OECD Perspective, (E. Reimer et al.
Kluwer Law 2014) at 86 ...

Base Erosion And Profit Shifting Beps

Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709407346
Size: 65.58 MB
Format: PDF, ePub
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23 et seq. E.g. J. Goede et al., Interpretation and Application of Art. 5 (Permanent
Establishment) of the OECD Model Tax Convention: Response from IBFD
Research Staff, 66 Bull. Intl. Taxn. 6 (2012), at 317, Journals IBFD; Reimer, in
Klaus Vogel on Double Taxation Conventions, supra n. 2, Article 5, para. 287.
E.g. Storck & Zeiler, supra n. 11, at 264 et seq.; E. Reimer, in Permanent
Establishments: A Domestic Taxation, Bilateral Tax Treaty and OECD
Perspective (E. Reimer et al. eds.

Judicial Interpretation Of Tax Treaties

Author: Carlo Garbarino
Publisher: Edward Elgar Publishing
ISBN: 1785365886
Size: 58.87 MB
Format: PDF, ePub
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Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how ...

The Taxation Of Permanent Establishments

Author: Radhakishan Rawal
Publisher: Spiramus Press Ltd
ISBN: 1904905455
Size: 56.51 MB
Format: PDF, Docs
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This book's principal theme is the taxation of permanent establishments, taking as its starting point the OECD (Organisation for Economic Co-operation and Development) model convention on the avoidance of double taxation, and examining how ...

The Oecd Model Convention And Its Update 2014

Author: Michael Lang
Publisher: Linde Verlag GmbH
ISBN: 3709406676
Size: 24.87 MB
Format: PDF, ePub, Mobi
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This book is designed to provide essential insights to academics, practitioners, tax officials and judges who deal or are interested in the field of international taxation.

Tax Treaty Interpretation

Author: Michael Lang
Publisher: Kluwer Law International
ISBN: 9041198571
Size: 59.75 MB
Format: PDF
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The relevance of the EC Treaty for the interpretation of tax treaty law - interaction
with Art. 24 OECD Model 1. Unsuccessful attempts to rely on the EC Treaty Under
Belgian domestic law, the taxable income of a foreign company with a permanent
establishment in Belgium that does not have a regular bookkeeping may be
established on the basis of lump-sum rules established by a Royal decree.24
Authors generally consider that those rules are contrary to the non-discrimination
 ...

Tax Treaties And Domestic Law

Author: Guglielmo Maisto
Publisher: IBFD
ISBN: 9076078920
Size: 39.52 MB
Format: PDF, ePub
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“Tax Treaties and Domestic Law provides an in-depth analysis of the relationship between tax treaties and domestic law.

Ec Tax Review

Author:
Publisher:
ISBN:
Size: 29.27 MB
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This stipulation reads: 'The taxation on a permanent establishment which an
enterprise of a Contracting State has in the other Contracting State shall not be
less favourably levied in that other State than the taxation levied on enterprises of
that other State carrying on the same activities'. The main question here is
whether this stipulation only covers taxation on the grounds of domestic law or
whether it extends to treaty benefits. The 1992 OECD report on 'Triangular Cases'
18 shed light ...