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Author: Fernando Souza de Man Publisher: ISBN: 9789087224219 Category : Taxation Languages : en Pages : 370
Book Description
The ease with which services are provided cross-border has increased considerably through the years, but this has not been reflected in the model conventions. Although this may not be an important issue when the flow of services between states is similar, it can have a huge impact on the collecting rights of states into which these services are mainly imported, such as developing countries. Nonetheless, developing countries? claims for more source taxation of services have been consistently neglected in model conventions.00With the intent of analysing whether the claims of developing countries are valid, as well as examining how the current system was structured, the author studies the legal and economic theories that support source and residence taxation and the historical documents concerning model conventions drafted by the League of Nations, the OECD and the United Nations. Furthermore, to better grasp the perspective of developing countries, the author analyses the situations of Brazil and India regarding the taxation of services in their domestic legislation and in their tax treaties, comparing the provisions of the latter with the current provisions in model tax conventions.
Author: Fernando Souza de Man Publisher: ISBN: 9789087224219 Category : Taxation Languages : en Pages : 370
Book Description
The ease with which services are provided cross-border has increased considerably through the years, but this has not been reflected in the model conventions. Although this may not be an important issue when the flow of services between states is similar, it can have a huge impact on the collecting rights of states into which these services are mainly imported, such as developing countries. Nonetheless, developing countries? claims for more source taxation of services have been consistently neglected in model conventions.00With the intent of analysing whether the claims of developing countries are valid, as well as examining how the current system was structured, the author studies the legal and economic theories that support source and residence taxation and the historical documents concerning model conventions drafted by the League of Nations, the OECD and the United Nations. Furthermore, to better grasp the perspective of developing countries, the author analyses the situations of Brazil and India regarding the taxation of services in their domestic legislation and in their tax treaties, comparing the provisions of the latter with the current provisions in model tax conventions.
Author: Kiyoshi Nakayama Publisher: International Monetary Fund ISBN: 1513577018 Category : Business & Economics Languages : en Pages : 27
Book Description
A well-designed regional tax treaty to which developing countries are signatories will include provisions securing minimum withholding taxes on investment income and technical service fees, a taxing right in respect of capital gains from indirect offshore transfers, and guarding against-treaty shopping. A tax treaty policy framework—national or regional—that specifies the main policy outcomes to be achieved before negotiations commence would enable developing countries with more limited expertise and lower capacity for tax treaty negotiations to avoid concluding problematic tax treaties. This note provides guidance for members of regional economic communities in the developing world on what should and should not be included in a regional tax treaty and how to design on a common tax treaty policy framework for use in negotiations of bilateral tax treaties with nonmembers.
Author: Kevin Holmes Publisher: IBFD ISBN: 9087220235 Category : Double taxation Languages : en Pages : 433
Book Description
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Author: Stanley S. Surrey Publisher: ISBN: Category : Developing countries Languages : en Pages : 136
Book Description
In 1967, the United Nations Group of Experts on Tax Treaties Between Developed and Developing Countries was established to facilitate the conclusion of tax treaties between developing and developes countries. This task was to be accomplished through the formation of guidelines for these treaties and recommendations for their implementation. This monograph describes the the work of this UN Group.
Author: United Nations. Department of International Economic and Social Affairs Publisher: ISBN: Category : Double taxation Languages : en Pages : 280
Book Description
Text of and commentaries on a model convention prepared under the auspices of the United Nations Ad Hoc Group of Experts on Tax Treaties between Developed and Developing Countries. The model consists of articles based on guidelines formulated by the Group at its various meetings and their commentaries expressed at those meetings together with commentaries, where appropriate, drawn from the OECD's 1977 Model Tax Convention.
Author: United Nations. Department of Economic and Social Affairs Publisher: New York : United Nations ISBN: Category : Double taxation Languages : en Pages : 80
Book Description
This publication contains guidelines consolidated from the previous reports prepared by the Group of Experts on Tax Treaties between Developed and Developing Countries, and it is designed as a handbook to assist the negotiation and to facilitate the conclusion of tax treaties.
Author: Patricia Brandstetter Publisher: IBFD ISBN: 9087220898 Category : Capital levy Languages : en Pages : 281
Book Description
"The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ('Taxes covered') of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpetive issues and uncertainties in practical treaty application. This book not only provides in-depth analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of today's tax treaties. The source documents used have rarely found their way into publications before: historical OEEC and OECD Reports and Minutes, originally largely classified as 'restricted' and thus inaccessible to the public for decades, provide an insight into the drafting process of Art. 2 and the discussions of Delegates from various nations on practical implications for treaty application. The book offers a unique perspective on this core treaty provision and aims to provide guidance for determing the 'taxes covered' in any tax treaty"--Page 4 of cover.
Author: United Nations. Department of Economic and Social Affairs Publisher: New York : United Nations ISBN: Category : Double taxation Languages : en Pages : 180
Book Description
Part one : report of the Ad Hoc Group of Experts on tax treaties between developed and developing countries on its sixth meeting. Part two : issues relating to tax treaties between developed and developing countries : report of the Secretary-General to the Ad Hoc Group of Experts.
Author: Fernando Souza de Man
Author: Fernando Souza de Man
Author: 
Author: Kiyoshi Nakayama
Author: Kevin Holmes
Author: Stanley S. Surrey
Author: United Nations. Department of International Economic and Social Affairs
Author: United Nations. Department of Economic and Social Affairs
Author: Patricia Brandstetter
Author: United Nations. Department of Economic and Social Affairs
Author: United Nations. Department of Economic and Social Affairs