“Tax Treaties and Domestic Law provides an in-depth analysis of the relationship between tax treaties and domestic law. It begins from an analysis of the topic from a constitutional and an international point of view, with a particular emphasis on the provisions laid down by Articles 26 and 27 of the Vienna Convention on the Law of Treaties. Special reports focus on tax treaty issues. In this context, specific problems raised by tax treaties are considered, such as treaty overrides and anti-abuse measures. The interaction between treaty provisions and domestic law is taken into consideration. Individual country surveys show how the issues raised by the relationships between tax treaties and domestic law are resolved by tax administrations and courts in selected European and non-European countries. A specific chapter is devoted to an analysis of how the relationships between tax treaties and domestic law can be improved in the fields of treaty override, treaty residence and anti-abuse measures.” -- Book jacket.
2018) Sheppard, Hale E., Esq., What Constitutes a “Willful” FBAR Violation?, 129 J. TAX'N 24 (Nov. 2018) Sheppard, Hale E., Alarming U.S. Tax Rules And Information-Reporting Duties For Foreign Retirement Plans: Problems And Solutions, ...
本书介绍了国际税收概览、国际税法原则、避免双重征税税收协定范本、国内税收制度的影响、反避税措施等内容。
This publication considers the interpretation of tax treaties primarily from the standpoint of public international law.
Rent-a-star – the object and purpose of Article 17(2) Also in 2002, the author published together with Harald Grams an article about the historical development of Article 17(2) and the excessive taxation that results from the reversal ...
This report may be considered the basic document on which double taxation conventions have been built for decades. See also 6. g. ... See for further discussion: Kemmeren, Principle of Origin in Tax Conventions (2001), pp. 12-14. 8.
The reports contained in this book address two questions.
The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of ...
This book aims at identifying and clarifying the most common issues emerging in the interpretation of multilingual tax treaties.
International Tax Law
Although this is a direct result of Switzerland's revised position regarding exchange of information, a number of contracting states have taken this opportunity to modify tax treaty benefits and/or clarify certain aspects of tax treaty ...