BN.com Gift Guide

Source Versus Residence: Problems Arising from the Allocation of Taxing Rights in Tax Treaty Law and Possible Alternatives

Hardcover (Print)
Buy New
Buy New from BN.com
$200.90
Used and New from Other Sellers
Used and New from Other Sellers
from $200.89
Usually ships in 1-2 business days
(Save 3%)
Other sellers (Hardcover)
  • All (7) from $200.89   
  • New (6) from $200.89   
  • Used (1) from $245.31   

Overview

One of the major objectives of tax treaties has been the avoidance of international double taxation. This is generally accomplished through the agreement of each country to limit, in specified situations set out in double tax treaties, its right to tax income earned from its territory by residents of another country.

The OECD Model Tax Treaty, other model conventions, and the bilateral treaties drafted in accordance with these models, allocate the taxing rights between the state of source and the state of residence. The source rules for income taxation are determined by Articles 6 through 21 of the OECD Model Convention. These rules are the product of a rather long history and it seems difficult to justify the scope of some in today’s world. Courts, tax administrators, and practitioners are confronted with a growing number of interpretation and application problems. In a globalized world with ever-increasing cross-border streams of income such problems command more and more attention.

This book is designed to analyze the allocation rules of the OECD Model Tax Convention and its equivalents in bilateral tax treaties. The distinguished contributors to the work examine the justification for these rules - as well as their scope – and highlight the most relevant interpretation and attendant application problems. In addition they’ll suggest how such rules should be modified and examine possible alternatives.

Read More Show Less

Product Details

  • ISBN-13: 9789041127631
  • Publisher: Kluwer Law International, BV
  • Publication date: 9/11/2008
  • Pages: 388
  • Product dimensions: 6.14 (w) x 9.21 (h) x 0.88 (d)

Table of Contents


Preface Chapter 1 Income from Immovable Property (Article 6 OECD Model Convention) Ekkehart Reimer Chapter 2 Business Profits (Article 7 OECD Model Convention) Reuven S. Avi-Yonah and Kimberly A. Clausing Chapter 3 Shipping, Inland Waterways Transport and Air Transport (Article 8 OECD Model Convention) Guglielmo Maisto Chapter 4 Notes on Guglielmo Maisto’s Paper on Article 8 OECD Model Convention Alexander Hemmelrath Chapter 5 Dividends (Article 10 OECD Model Convention) Stef van Weeghel Chapter 6 Discussion of Stef van Weeghel’s Paper on Article 10 OECD Model Convention Marjaana Helminen Chapter 7 Interest (Article 11 OECD Model Convention) Robert Danon Chapter 8 Royalties (Article 12 OECD Model Convention) Niv Tadmore Chapter 9 Capital Gains (Article 13 OECD Model Convention) Stefano Simontacchi Chapter 10 Discussion of Stefano Simontacchi’s Paper on Article 13 OECD Model Convention Richard Krever Chapter 11 Income from Employment (Article 15 OECD Model Convention) Robert Waldburger Chapter 12 Directors’ Fees (Article 16 OECD Model Convention) Rainer Prokisch Chapter 13 Artistes and Sportsmen (Article 17 OECD Model Convention) Daniel Sandler Chapter 14 Discussion of Daniel Sandler’s Paper on Article 17 OECD Model Convention Dick Molenaar Chapter 15 Pensions (Article 18 OECD Model Convention) Eric C.C.M. Kemmeren Chapter 16 Government Service (Article 19 OECD Model Convention) Pasquale Pistone Chapter 17 Students (Article 20 OECD Model Convention) Luc De Broe Chapter 18 Other Income (Article 21 OECD Model Convention) Alexander Rust Chapter 19 Discussion of Alexander Rust’s Paper on Article 21 OECD Model Convention Frank Pötgens and Alexander Bosman Index

Read More Show Less

Customer Reviews

Be the first to write a review
( 0 )
Rating Distribution

5 Star

(0)

4 Star

(0)

3 Star

(0)

2 Star

(0)

1 Star

(0)

Your Rating:

Your Name: Create a Pen Name or

Barnes & Noble.com Review Rules

Our reader reviews allow you to share your comments on titles you liked, or didn't, with others. By submitting an online review, you are representing to Barnes & Noble.com that all information contained in your review is original and accurate in all respects, and that the submission of such content by you and the posting of such content by Barnes & Noble.com does not and will not violate the rights of any third party. Please follow the rules below to help ensure that your review can be posted.

Reviews by Our Customers Under the Age of 13

We highly value and respect everyone's opinion concerning the titles we offer. However, we cannot allow persons under the age of 13 to have accounts at BN.com or to post customer reviews. Please see our Terms of Use for more details.

What to exclude from your review:

Please do not write about reviews, commentary, or information posted on the product page. If you see any errors in the information on the product page, please send us an email.

Reviews should not contain any of the following:

  • - HTML tags, profanity, obscenities, vulgarities, or comments that defame anyone
  • - Time-sensitive information such as tour dates, signings, lectures, etc.
  • - Single-word reviews. Other people will read your review to discover why you liked or didn't like the title. Be descriptive.
  • - Comments focusing on the author or that may ruin the ending for others
  • - Phone numbers, addresses, URLs
  • - Pricing and availability information or alternative ordering information
  • - Advertisements or commercial solicitation

Reminder:

  • - By submitting a review, you grant to Barnes & Noble.com and its sublicensees the royalty-free, perpetual, irrevocable right and license to use the review in accordance with the Barnes & Noble.com Terms of Use.
  • - Barnes & Noble.com reserves the right not to post any review -- particularly those that do not follow the terms and conditions of these Rules. Barnes & Noble.com also reserves the right to remove any review at any time without notice.
  • - See Terms of Use for other conditions and disclaimers.
Search for Products You'd Like to Recommend

Recommend other products that relate to your review. Just search for them below and share!

Create a Pen Name

Your Pen Name is your unique identity on BN.com. It will appear on the reviews you write and other website activities. Your Pen Name cannot be edited, changed or deleted once submitted.

 
Your Pen Name can be any combination of alphanumeric characters (plus - and _), and must be at least two characters long.

Continue Anonymously

    If you find inappropriate content, please report it to Barnes & Noble
    Why is this product inappropriate?
    Comments (optional)