Interpretation And Application Of Tax Treaties

Author : Juan Angel Becerra
Publisher : IBFD
ISBN 13 : 9087220197
Total Pages : 299 pages
Book Rating : 4.98/5 ( download)

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Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.

Author : F. A. Engelen
Publisher : IBFD
ISBN 13 : 9076078726
Total Pages : 615 pages
Book Rating : 4.24/5 ( download)

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Download or read book Interpretation of Tax Treaties under International Law written by F. A. Engelen and published by IBFD. This book was released on 2004 with total page 615 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication considers the interpretation of tax treaties primarily from the standpoint of public international law. The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are therefore central to this study. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international court and tribunals. Considers also the extent to which the relevant rules and principles of international law are binding on domestic court and taxpayers. The importance of international law for the purpose of the interpretation of tax treaties is illustrated by a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).

Author : Ned Shelton
Publisher :
ISBN 13 : 9780406958457
Total Pages : 662 pages
Book Rating : 4.59/5 ( download)

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Download or read book Interpretation and Application of Tax Treaties written by Ned Shelton and published by . This book was released on 2004 with total page 662 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an excellent, practical resource for international tax practitioners no matter where they are located. Looking at tax treaties from a practical and planning point of view, the book provides an insight into treaty interpretation and application in a number of countries. Other highlights include case studies and OECD model treaties. Written by an expert in the field and taking the practical approach rather than the academic, this truly is an essential global tool for the tax adviser wishing to use tax treaties in tax planning.

Author : Carlo Garbarino
Publisher : Edward Elgar Publishing
ISBN 13 : 1785365886
Total Pages : 699 pages
Book Rating : 4.81/5 ( download)

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Download or read book Judicial Interpretation of Tax Treaties written by Carlo Garbarino and published by Edward Elgar Publishing. This book was released on 2016-10-28 with total page 699 pages. Available in PDF, EPUB and Kindle. Book excerpt: Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.

Author : United States. Internal Revenue Service
Publisher :
ISBN 13 :
Total Pages : 28 pages
Book Rating : 4.27/5 ( download)

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Download or read book U.S. Tax Treaties written by United States. Internal Revenue Service and published by . This book was released on 1990 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author : Richard Xenophon Resch
Publisher : Tredition Gmbh
ISBN 13 : 9783347058835
Total Pages : 288 pages
Book Rating : 4.36/5 ( download)

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Download or read book Tax Treaty Interpretation written by Richard Xenophon Resch and published by Tredition Gmbh. This book was released on 2020-05-05 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt: This study clarifies the meaning and application of Article 3(2) of the OECD Model Tax Convention on Income and on Capital. It maps the entire historical debate on the provision, illuminates flawed assumptions and misunderstandings in its course, and outlines how these continue to fuel the current controversies. In addition, it provides a comprehensive analysis of German case law concerning the interpretation of tax treaties and examines the extent to which the German Federal Fiscal Court has been influenced by views developed in doctrine. Finally, it clarifies the relationship between Article 3(2) and the rules on treaty interpretation codified in the Vienna Convention on the Law of Treaties, the meaning of 'context', and how the condition 'unless the context otherwise requires' is to be applied. Thereby, an approach is submitted that is firmly based on public international law principles and transcends the current controversies into a holistic synthesis.

Author : Kevin Holmes
Publisher : IBFD
ISBN 13 : 9087220235
Total Pages : 433 pages
Book Rating : 4.35/5 ( download)

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Download or read book International Tax Policy and Double Tax Treaties written by Kevin Holmes and published by IBFD. This book was released on 2007 with total page 433 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 :
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.18/5 ( download)

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Download or read book Interpretation and Application of Tax Treaties in North America (Second Revised Edition) written by and published by . This book was released on with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author :
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.15/5 ( download)

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Download or read book Interpretation and Application of Tax Treaties in North America 2nd edition written by and published by . This book was released on with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Author : Guglielmo Maisto
Publisher : IBFD
ISBN 13 : 9087220138
Total Pages : 435 pages
Book Rating : 4.36/5 ( download)

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Download or read book Courts and Tax Treaty Law written by Guglielmo Maisto and published by IBFD. This book was released on 2007 with total page 435 pages. Available in PDF, EPUB and Kindle. Book excerpt: A detailed and comprehensive study of the issues faced by judiciaries when dealing with tax treaty law cases. It begins with an overview of some of the questions that domestic courts have to deal with when facing treaty cases. It then provides a comparative look into the structure of tax judiciaries and the issues raised by the burden of proof in cases dealing with the application of tax treaties. The different approaches of judiciaries of common law and civil law countries are also taken into consideration. A particular focus is devoted to the interaction between European law principles and bilateral tax treaties, both from the point of view of national judges and the Court of Justice of the European Communities, as well as the relevance of foreign court decision in interpreting tax treaties and the twofold influence between decisions issued by national courts and the Commentaries to the OECD Model Tax Convention. Individual country surveys provide an in-depth analysis on how national courts face cases dealing with the application of tax treaties, with a particular emphasis on issues raised by tax treaty interpretation. Lastly, the book deals with issues raised by judicial treaty override, proposes solutions to resolve judicial errors in the context of international tax law and analyses the procedural conditions for the implementation of tax treaty obligations under domestic law.