Taxation Convention with Australia PDF Download

Author: Australia
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 14

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Book Description

Author: Jonathan Schwarz
Publisher: Kluwer Law International B.V.
ISBN: 9403526319
Category : Law
Languages : en
Pages : 870

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Book Description
Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.

Author: OECD
Publisher: OECD Publishing
ISBN: 9264287957
Category :
Languages : en
Pages : 658

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Book Description
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...

Author: OCDE,
Publisher: OCDE
ISBN: 9789264241213
Category : Double taxation
Languages : en
Pages : 48

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Book Description
This report includes changes to the definition of permanent establishment in the OECD Model Tax Convention that will address strategies used to avoid having a taxable presence in a country under tax treaties. These changes will ensure that where the activities that an intermediary exercises in a country are intended to result in the regular conclusion of contracts to be performed by a foreign enterprise, that enterprise will be considered to have a taxable presence in that country unless the intermediary is performing these activities in the course of an independent business. The changes will also restrict the application of a number of exceptions to the definition of permanent establishment to activities that are preparatory or auxiliary nature and will ensure that it is not possible to take advantage of these exceptions by the fragmentation of a cohesive operating business into several small operations; they will also address situations where the exception applicable to construction sites is circumvented through the splitting-up contracts between closely related enterprises.

Author: C. C. H. Editors
Publisher:
ISBN: 9781925894233
Category :
Languages : en
Pages :

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Book Description
Expanding on key topics and legislation from the Australian Master Tax Guide, this title guides students through the operation of tax law by way of over 220 case study type examples, updated to the 2018/19 tax year, that relate to situations they can expect to encounter in practice.KEY FEATURESEach example covers the type of day-to-day situation that clients often present to their adviser, delivered in a case study type format with an 'Issue' and a 'Solution' along with cross-references to paragraphs in the Australian Master Tax Guide enabling a particular taxation issue to be explored in detail. The examples cover the 12 following topics:Administration and AssessmentAssessable incomeCapital gains taxCompanies and distributionsDeductionsDepreciationFringe benefits taxGoods and services taxIndividualsPartnershipsTrading StockTrustsOxford University Press Australia & New Zealand is the non-exclusive distributor of this title.

Author: Sunita Jogarajan
Publisher: Cambridge University Press
ISBN: 1108383742
Category : Law
Languages : en
Pages : 356

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Book Description
Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.

Author: OECD
Publisher: OECD Publishing
ISBN: 9264202714
Category :
Languages : en
Pages : 44

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Book Description
This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

Author: John Bevacqua
Publisher: Wiley
ISBN: 9780730385653
Category :
Languages : en
Pages : 472

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Book Description
The first edition of Australian Taxation is written with accounting students in mind. The text is concise and to the point, is easy to digest and is applied rather than legalistic. It aims to demystify legal jargon and legal technicality without sacrificing essential core legal knowledge and meaning. Importantly, it provides the requisite foundation for business students who intend to later undertake the professional programs of either CPA Australia or CA ANZ. Academics and students get the best of both print and digital with our unique offering, which allows for more opportunities for self-study and flexible learning. The E-Text format is ideal for blended learning and features a range of instructional media content designed to provide students with an interactive and engaging learning experience.

Author: United States. Congress. Senate. Committee on Foreign Relations
Publisher:
ISBN:
Category : Double taxation
Languages : en
Pages : 66

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Book Description

Author: Pagone
Publisher:
ISBN: 9781760021689
Category :
Languages : en
Pages :

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Book Description
The book provides a guide to tax disputes in Australia. It explains the process of tax objections and appeals, and the limitations to collateral challenges. Separate chapters consider the rules applicable to tax disputes brought in the Federal Court and in the Administrative Appeals Tribunal, and ancillary issues of discovery and access to information. The book aims also to provide helpful assistance to the practitioner and to students in the preparation of submissions, persuasive advocacy and the provision to courts and tribunals of useful expert evidence in support of disputed positions.