Suchen und Finden
List of Contributors
Personal and Substantive Scope (Art 1, 2 and 4 OECD Model)
Germany: Consequences of a Treaty Override?
Australia: Puppet Boards – Where is Central Management and Control Exercised and Where is the Place of Effective Management?
Sweden: Non-taxable Collective Investment Vehicles Determined Resident under Sweden-Spain Income Tax Treaty
United States: Abandonment of Residence Status
Business profits and permanent establishments (Art 5, 6, 7, 8 and 14 OECD Model)
Finland: Allocation of Subsidiary Share Related Loans to a PE
Japan: The Procedural Requirements for Applying a Treaty and Determination of a Permanent Establishment for an Online Sales Business
Poland: Can a Tax Authority Change the Qualification of Items of Income of a Taxpayer as a Resultof a Double Taxation Convention Providing for Qualification in Accordance with Domestic Tax Law?
Portugal: Domestic Losses and Worldwide Gross Income
Belgium: Transparent Entities: The Case of the French SCI under the Belgium-French Tax Treaty
Associated Enterprises (Art 9 OECD Model)
India: If there is a Transaction between Associated Enterprises, ALP Adjustment has to be made and the Contention that there will be overall Erosion of the Indian Tax Base is not relevant
United States: Narrow ALS Analysis
United States: It is Permissible to Apply the ALS on a Consolidated Basis
Dividend and interest (Art 10 and Art 11 OECD Model)
Argentina: Treaty Abuse and Beneficial Ownership – the Molinos Case
Czech Republic: Application of the Abuse of Law Concept in Business Restructuring
Poland: Can a Leader in a Cash Pooling System be Recognized as the Beneficial Owner of the Interest in the Meaning of Tax Treaty Law?
Spain: Dividends, Leveraged Buyouts and the Concept of Abuse / Simulation in Domestic Law, EU Law and Tax Treaties
Brazil: Taxation of Controlled Foreign Companies in Brazil – Still a Case for Article 7
Italy: The Concept of Beneficial Ownership in Tax Treaties and its General Anti-Avoidance Function
Royalties and Capital Gains (Art 12 and 13 OECD Model)
Bulgaria: Procedural Requirements for Tax Treaty Relief: a “Penalty” for Tax Treaty Application
Australia: Limitations on applying the royalties Article in a digital era
Kazakhstan: Kazmunaiservices & Contracting Case on Technical Services and the MFN Clause
Estonia: Dalkia International S.A.
Turkey: Characterization of Cost Contribution Agreement Fees
Employment Income (Art 15, 18 and 19 OECD Model)
China: Employment Income Received from Outside of China (Article 15 of the OECD Model)
Luxembourg: Taxation of Flight Personnel in Triangular Situations and Article 15(3) of theOECD Model
United Kingdom: Do the Activities of an Employed North Sea Diver Fall within Article 7 or 14 of the UK-South Africa Tax Treaty?
Netherlands: The Impact on Tax Treaties of a Legal Fiction included in National Tax Law (the “customary wage rule”)
Directors’ fees, Artistes and Sportsmen, Students and Other Income, Methods to Avoid Double Taxation (Art 16, 17, 20, 21 and Art 23 OECD Model Convention)
Portugal: Artistes’ and Sportsmen’s Income
Sweden: Taxation of Income from Entertainment and Sporting Activities
Canada: Limitation on Elimination of Double Taxation under the Canada-Brazil Income Tax Treaty
Norway: The Remittance Rule in the Tax Treaty between Norway and Singapore
Israel: The Relationship between Domestic Law and the Tax Treaty in the Interpretation of the Relief from Double Taxation Article
Non-discrimination, mutual agreement and mutual assistance (Art 24–27 OECD Model Convention)
India: Non-Discrimination Clause Extends Exemption from Capital Gains in case of Foreign Amalgamation involving Indian Assets
United States: Assistance in the Collection of Taxes
Canada: Judicial Review of the Canada Revenue Agency’s Response in a Mutual Agreement Procedure under the Canada-United States Tax Treaty
Switzerland: Demarcation between an Acceptable Group Request and an Unacceptable “Fishing Expedition”
Russia: Thin Capitalization, Recharacterization of Interest as Dividends and the Non-Discrimination Article
Series on International Tax Law