"This book is the seventh volume in the IBFD EC and International Tax Law Series, which includes monographs focussing on issues of interpretation of EU tax and treaty laws with particular attention to the interaction between tax law and ...
43484 bis, case X Holding BV v. Staatssecretaris van Financiën, para. 4.5. See Joachim Englisch, 'X Holding: Looking beyond Loss Relief Issues', in D. Weber & B. da Silva (eds) From Marks & Spencer to X Holding: The Future ...
Session Seton Hall J. Sports L. Seton Hall J. Sports & Ent. L. SICAV Skat Ud Skatt Ov. SLT SMAA SNEs SOFA SOT Sp. ... Denmark) Sports Law & Taxation (periodical, Netherlands; formerly: Global Sports Law and Taxation Reports) Sample ...
... phenomenon prevailing under the current international approach to the taxation of cross-border dividends because of ... That is, withholding taxes are typically imposed at full rates on dividends paid to non-treaty countries and yet ...
DE: BFH [Bundesfinanzhof] (Federal Fiscal Court), 9 February 2011, Nos. IR 54/10, IR 55/10, Tax Treaty Case Law IBFD. 16. Convention between the United Kingdom of Great Britain and Northern Ireland and the Federal Republic of Germany ...
This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics."
... (Alphen aan den Rijn: Kluwer Law International, 2007). B. Woodward and S. Armstrong, The Brethren: Inside the Supreme Court (New York: Simon and Schuster, 1979). K. Wright, California Income Tax Manual (Chicago: CCH, 2008).
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 ...
says that a treaty should be interpreted according to the contemporary interpretation of its terms rather than by ... The Meaning of 'Enterprise,' 'Business,' and 'Business Profits'under Tax Treaties and EU Tax Law (IBFD 2011). case of ...
692 See Giuseppe Persico, “Agency Permanent Establishment under Article 5 of the OECD Model Convention,” Intertax (2000) p. 68. 693 See John F. Avery Jones/Jürgen Lüdicke, World Tax Journal, (2014) p. 206, Jean Schaffner, How Fixed Is a ...
The Meaning of 'Enterprise', 'Business' and 'Business Profits' under Tax Treaties and EU Tax Law, vol. 7, 41–58 (IBFD, EC and International Tax Law Series, 2011). Jacques Sasseville and Richard J. Vann, IBFD Global Tax Treaty ...