Author: League of NationsPublisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 26
Book Description
Double Taxation and Fiscal Evasion
Author: League of NationsPublisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 26
Book Description
Double Taxation and Fiscal Evasion
Author: League of Nations. Secretariat. Economic and Financial SectionPublisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 352
Book Description
State and Local Taxation
Author: National Tax AssociationPublisher:
ISBN:
Category : Local taxation
Languages : en
Pages : 542
Book Description
Double Taxation Relief
Author: Mitchell Benedict CarrollPublisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 36
Book Description
Digest and Index
Author: National Tax AssociationPublisher:
ISBN:
Category : Taxation
Languages : en
Pages : 540
Book Description
Legislative History of United States Tax Conventions
Author: United States. Congress. Joint Committee on Internal Revenue TaxationPublisher:
ISBN:
Category : Aliens
Languages : en
Pages : 726
Book Description
Legislative History of United States Tax Conventions: Income tax conventions, Secs. 12-25
Author: Trade Information Bulletin
Author: American Problems of Reconstruction
Author: Elisha M. FriedmanPublisher: New York : E.P. Dutton
ISBN:
Category : Industrial efficiency
Languages : en
Pages : 540
Book Description
Other Income under Tax Treaties
Author: Alexander BosmanPublisher: Kluwer Law International B.V.
ISBN: 9041166203
Category : Law
Languages : en
Pages : 637
Book Description
Bilateral tax treaties are often, to a greater or lesser extent, based on the OECD Model Convention. Among the distributive rules with respect to taxation of income which are laid down in Chapter III of that model, Article 21 assigns the tax jurisdiction in respect of "other income" - understood to mean items of income which are not dealt with in other provisions of the tax treaty - to the residence state in accordance with the main rule underlying the OECD Model, thus ensuring that no income falls outside the scope of the treaty. This study provides a comprehensive analysis of Article 21 of the OECD Model. In extensive detail, and with reference to case law from a number of jurisdictions and to statements of various authorities and official documents, the author shows how Article 21 operates in relation to the other distributive rules of the OECD Model and bilateral tax treaties based thereon. The analysis considers such items of income as the following in relation to Article 21: - income from immovable property; - business profits; - profits from shipping, inland waterways transport, and air transport; - dividends, interest, and royalties; - capital gains; and - income from employment. In addition, the author examines the significance of the OECD Commentaries for the interpretation of tax treaties, the "other income" article in other model conventions, and notable deviations from Article 21 among bilateral tax treaties. An appendix offers well-grounded recommendations on how to potentially amend the wording of Article 21 and the related commentary and how the application of the article can be improved. Although underexposed in the tax law literature heretofore, the "other income" article raises important international taxation issues that remain problematic or unresolved. Tax lawyers, government officials, and other interested professionals will find here a penetrating analysis that goes a long way towards clarifying the characterisation of income that resists the standard categories defined in tax treaties.