How domestic anti-avoidance rules affect double taxation conventions
Read Online
Share

How domestic anti-avoidance rules affect double taxation conventions proceedings of a seminar held in Toronto, Canada, in 1994 during the 48th Congress of the International Fiscal Association by

  • 403 Want to read
  • ·
  • 56 Currently reading

Published by Kluwer Law International in The Hague, Boston .
Written in English

Subjects:

  • Double taxation -- Congresses.,
  • Double taxation -- Treaties -- Congresses.,
  • Tax shelters -- Congresses.,
  • Tax evasion -- Congresses.

Book details:

Edition Notes

Includes bibliographical references.

StatementInternational Fiscal Association.
SeriesIFA congress seminar series ;, vol. 19c, IFA congress seminar series ;, 19c.
ContributionsInternational Fiscal Association., International Fiscal Association. Congress
Classifications
LC ClassificationsK4474.6 1995
The Physical Object
Paginationix, 50 p. ;
Number of Pages50
ID Numbers
Open LibraryOL785710M
ISBN 109041100709
LC Control Number95017921

Download How domestic anti-avoidance rules affect double taxation conventions

PDF EPUB FB2 MOBI RTF

“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. The Application of Domestic General Anti-Abuse Rules under Double Tax Agreements General anti-avoidance measures can generally be divided into two categories based on the way they counteract abuse The first category consists of anti-avoidance rules under which tax . general anti-avoidance provision. Significant changes were made to the Commentary to the OECD Model in The OECD intended that this revision would clarify the relationship between tax treaties and domestic anti-avoidance rules. Central to this change was the clear statement that "it is also a purpose of tax conventions toCited by: 2. as judicial doctrines, statutory general anti-avoidance rules or statutory specific anti-avoidance rules. The issue then arises as to what is the impact of tax treaties on such domestic anti-avoidance rules. In general, it is accepted that tax treaties are rules that limit domestic law and if a conflict arises between the domestic law and tax.

  General Anti-Avoidance Rules and Double Tax Agreements: A New Zealand Perspective Revenue Law Journal, Vol. 19, No. 1, Article 4, 16 Pages Posted: 22 Nov Last revised: 11 Jul The politics and tax legislation being a manifestation of strict sovereignty of the State, the phenomenon of double taxation occurs frequently representing a difficult poison for the foreign trade.   The Worldwide Network of Bilateral Double Tax Conventions. The first modern double tax convention goes back to when Prussia and Austria-Hungary signed such a treaty (Easson ).Since then, the number of treaties has been rising steadily; at the beginning, mostly industrialized countries entered into such treaties with each other. The international double taxation occurs when one and the same taxable object is subject to taxation in two or more states, for one and the same time period. Legal means of disposal of such conflicts on international scale are tax Conventions, called international double tax.

Get this from a library! How domestic anti-avoidance rules affect double taxation conventions: proceedings of a seminar held in Toronto, Canada, in during the 48th Congress of the International Fiscal Association. [International Fiscal Association.; International Fiscal Association. DTT provisions invoking domestic anti-avoidance rules; one of the aims of double tax conventions or treaties (DTTs) is to prevent avoidance and evasion. However the very existence of a DTT could facilitate avoidance cross-border by securing the benefit of a domestic tax advantage and a relief from tax under a DTT. The update to the. Tax treaties, and model conventions, generally do not include any guidance on how the provisions of treaties should be applied, 1 A/RES/63/, annex, paras. 16 and Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This new Fourth Edition has been completely revised and updated to give you a full and current account of double tax conventions (DTCs).. DTCs form the backbone of international taxation, but they raise many interpretational questions.