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Author: Michael Lang Publisher: ISBN: 9789041127631 Category : Aliens Languages : en Pages : 0
Book Description
The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Author: Michael Lang Publisher: ISBN: 9789041127631 Category : Aliens Languages : en Pages : 0
Book Description
The book analyses the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The contributors examine the justification for these rules - as well as their scope - and highlight the most relevant interpretation and attendant application problems. In addition they suggest how such rules should be modified and examine possible alternatives.
Author: Jaivir Singh Publisher: Berghahn Books ISBN: 9788187358282 Category : Business & Economics Languages : en Pages : 266
Book Description
A Large Body Of Standard Literature On Regulation Has Grown Organically In Response To The Markets In The United States And Western Europe. The Twelve Papers In Regulation, Institutions And The Law Try To Understand The Specific Context Within Which Regulation Has Unfolded In A Country Like India, Which Is Different In Many Ways From That Of The United States And Western Europe. The Volume Also Dwells On How These Regulatory Issues Flow Across National Boundaries And Affect The International Arena In This Age Of Globalization. Jaivir Singh Teaches At The Centre For The Study Of Law And Governance, Jawaharlal Nehru University, New Delhi. He Has Published Articles On The Economics Of Labour Law, Competition Policy, Regulation, Legal Procedure, Judicial Activism And Separation Of Powers, And Is The Author Of 'Central Government Policies: Interface With Competition Policy Objectives' In Pradeep S. Mehta Ed., Towards A Functional Competition Policy For India (Jaipur: Cuts International 2005).
Author: Dale Pinto Publisher: IBFD ISBN: 9076078564 Category : Electronic commerce Languages : en Pages : 260
Book Description
The advent of electronic commerce has caused many to question the continued viability of sourced-based taxation. This thesis argues that source-based taxation is theoretically justifiable for income that arises from international transactions which are conducted in an electronic commerce environment.
Author: Eric Kemmeren Publisher: ISBN: 9789087227111 Category : Double taxation Languages : en Pages : 380
Book Description
This publication gives a global overview of international tax disputes on double tax conventions. It covers the 32 most important tax treaty cases which were decided around the world in 2019. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases.
Author: Jacob A. Frenkel Publisher: MIT Press ISBN: 9780262061438 Category : Business & Economics Languages : en Pages : 268
Book Description
In this book the authors provide a new treatment of international taxation, one that focuses on the interactions between fiscal policies of sovereign nations and the magnitude and directions of international capital and goods flow in an integrated world economy.
Author: Mr.Parthasarathi Shome Publisher: International Monetary Fund ISBN: 9781557754905 Category : Business & Economics Languages : en Pages : 336
Book Description
Edited by Parthasarathi Shome, this Handbook was written primarily for economists who are responsible for analyzing and evaluating economic policies of developing countries at an applied level, and who would benefit from a comprehensive discussion of the concepts, principles, and prevailing issues of taxation.
Author: Ajit Kumar Singh Publisher: Kluwer Law International B.V. ISBN: 9403533641 Category : Law Languages : en Pages : 234
Book Description
In an age when cross-border business transactions are increasingly effected without the transference of physical products, revenue concerns of states have led to a multitude of tax disputes based on the concept of ‘nexus’. This important and timely book is the most authoritative to date to discuss one of the major tax topics of our time – the question of how taxing rights on income generated from cross-border activities in the digital age should be allocated among jurisdictions. Demonstrating in prodigious depth that it is the economic nexus of the tax entity or activity with the state, and not the physical nexus, which meets the jurisdictional requirement, the author – a leading authority on this area who is a Senior Commissioner of Income Tax and a Member of the Dispute Resolution Panel of the Government of India – addresses such dimensions of the subject as the following: whether a strict territorial nexus as a normative principle is ingrained in source rule jurisprudence; detailed scrutiny of such classical doctrines as benefit theory, neutrality theory, and internation equity; comparative critique of the Organisation for Economic Co-operation and Development (OECD) and United Nation (UN) model tax treaties; whether international law and customary principles mandate a strict territorial link with the source state for the assumption of tax jurisdiction; whether the economic nexus-based tax jurisdiction and absence of a physical presence breach the constitutional doctrine of extraterritoriality or due process; and whether retrospective tax legislation breaches the principle of constitutional fairness. The book offers a politically informed analysis of the nexus principle and balances the dynamics of physical presence and economic nexus standards, based on an in-depth survey of the historical evolution of judicial pronouncements and international practices in this regard. Dr Singh’s book exposes an urgently needed missing link in the international source rule literature and takes a giant step towards solving the thorny question of appropriate tax apportionment. It sheds brilliant light on the policies states may adopt when signing new tax treaties, so that unintended results may be foreseen and avoided. Tax practitioners, taxation authorities, and academic researchers in the field of international tax law and policy will greatly appreciate the book’s forthright enhancement of the ability to defend challenges based on the nexus doctrine.
Author: Michael Lang
Author: Michael Lang
Author: 
Author: 
Author: Jaivir Singh
Author: Dale Pinto
Author: Robert J. Waschbusch
Author: Eric Kemmeren
Author: Jacob A. Frenkel
Author: Mr.Parthasarathi Shome
Author: Ajit Kumar Singh