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Author: Catherine A. Brown Publisher: Canadian Tax Foundation = Association Canadienne d'études fiscales ISBN: Category : Business & Economics Languages : en Pages : 476
Book Description
A study discussing tax aspects of the transfer of technology by non-residents to seven countries in the Asia-Pacific which have both the interest in acquiring it and the capability of exploiting it: Indonesia, Singapore, Malaysia, Thailand, China, Hong Kong and Taiwan. For each country the author reviews the domestic withholding tax provisions, examines the interaction of these provisions with the relevant double taxation agreement and discusses government policies and tax incentives related thereto. Some relevant parts of legislation are also appended.
Author: Catherine A. Brown Publisher: Canadian Tax Foundation = Association Canadienne d'études fiscales ISBN: Category : Business & Economics Languages : en Pages : 476
Book Description
A study discussing tax aspects of the transfer of technology by non-residents to seven countries in the Asia-Pacific which have both the interest in acquiring it and the capability of exploiting it: Indonesia, Singapore, Malaysia, Thailand, China, Hong Kong and Taiwan. For each country the author reviews the domestic withholding tax provisions, examines the interaction of these provisions with the relevant double taxation agreement and discusses government policies and tax incentives related thereto. Some relevant parts of legislation are also appended.
Author: Eduardo Baistrocchi Publisher: Cambridge University Press ISBN: 1139916289 Category : Law Languages : en Pages : 975
Book Description
Via a global analysis of more than 180 transfer pricing cases from 20 representative jurisdictions, Resolving Transfer Pricing Disputes explains how the law on transfer pricing operates in practice and examines how disputes between taxpayers and tax administrations are dealt with around the world. It has been designed to be an essential complement to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which focus on transfer pricing issues but do not refer to specific transfer pricing disputes. All of the transfer pricing cases discussed in the book are linked to the relevant paragraphs of the OECD Guidelines by means of a 'Golden Bridge', namely a table listing the cases according to the paragraphs of the Guidelines to which they refer. It therefore provides examples of the application of the Arm's Length Principle in many settings on all continents.
Author: Klaus Vogel Publisher: Springer ISBN: Category : Business & Economics Languages : en Pages : 1736
Book Description
Full Title: Klaus Vogel on Double Taxation Conventions, Third Edition, A Commentary to the OECD, UN and U.S. Model Conventions for the Avoidance of Double Taxation of Income and Capital, With Particular Reference to German Treaty Practice A Commentary to the OECD, UN and U.S. Model Conventions for the Avoidance of Double Taxation of Income and Capital, With Particular Reference to German Treaty Practice. Double taxation conventions (DTCs) raise a plethora of interpretational questions for the practitioner and student of tax law. This book provides the answers. An encyclopedic treatise on DTCs, Klaus Vogel on Double Taxation Conventions is a guide to all legal issues DTCs raise and includes information on worldwide case law and commentators' views. The OECD Model Convention serves as the organisational basis for this work. Each chapter focuses on one article of the Convention and provides: the wording of the article and that of the respective articles of the UN and US Models, the official Commentary by OECD, and an extensive discussion by the authors of the legal problems involved. In addition, Klaus Vogel on Double Taxation Conventions offers an account of all German tax treaties, how they differ from the model provisions, and the potential practical impact of such differences. The first two editions have been used by lawyers, tax advisers, and scholars all over the world. Courts in Canada, Germany, South Africa, and the Netherlands have cited them as authority. This revised edition includes the most recent OECD Model revisions and all recent case law and relevant literature. The authors have rethought many of the problems discussed, further improved their argument, and amended their views where they have been convinced by opponents.
Author: United Nations Conference on Trade and Development Publisher: United Nations Publications ISBN: Category : Political Science Languages : en Pages : 68
Book Description
"The report gives an overview of the impact of taxation in developed and developing countries on the transfer of technology and seeks to shed light on the formulation of tax policies that could facilitate technology transfer"--Page iii.
Author: Catherine A. Brown
Author: Catherine A. Brown
Author: United States. Congress. Senate. Committee on Foreign Relations
Author: Eduardo Baistrocchi
Author: Guillermo Cabanellas
Author: National Tax Association
Author: United States. Congress. Senate. Committee on Foreign Relations
Author: National Tax Association-Tax Institute of America
Author: Klaus Vogel
Author: International Fiscal Association
Author: United Nations Conference on Trade and Development