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Income from International Private Employment
This study considers the treatment of income from private employment under tax treaties containing provisions analogous or similar to Article 15 of the OECD Model.
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- Title:
Income from International Private Employment. Doctoral Series - Vol. 12
- Author(s):
Frank Pötgens
- Date of publication:
January 2007
- ISBN:
978-90-8722-001-3
- Type of publication:
Book
- Number of pages:
1056
- Terms:
Price includes delivery. View purchase information
- Price:
- € 150 / $ 190 (VAT excl.)
- tab_1
- Title:
Income from International Private Employment. Doctoral Series - Vol. 12
- Author(s):
Frank Pötgens
- Date of publication:
January 2007
- ISBN:
978-90-8722-001-3
- Type of publication:
Online book
- Number of pages:
1056
- Access:
Up to five users. View purchase information
- Price:
- € 150 / $ 190 (VAT excl.)
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Special offer
Order 2 books from the Doctoral Series and receive a 20% discount. Order 3 or more books and receive a 30% discount. Not available in combination with any other discount. Single copy only.
- Income from International Private Employment
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Why this book?
This study considers the treatment of income from private employment under tax treaties containing provisions analogous or similar to Article 15 of the OECD Model. It offers an in-depth analysis of these provisions as well as suggestions for improvements in the application and interpretation.It approaches the analysis of Article 15 of the OECD Model from the perspective of five key countries: Belgium, Germany, the Netherlands, the United Kingdom and the United States. By analysing case law, legal literature and official policy statements of these countries' respective tax authorities, the study also describes potential difficulties.An overview is provided of the various interpretations and explanations employed in these countries, which is also used by the author in developing a preferred interpretation of a term at issue.Downloads
This book is part of the IBFD Doctoral Series
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Downloads
Main contents
- Chapter 1: Introduction
- Chapter 2: History
- Chapter 3: Interpretation
- Chapter 4: Some residence issues connected with regimes applying to expatriates
- Chapter 5: The first rule of Article 15 of the OECD Model (Art. 15 (1), first part of the first sentence)
- Chapter 6: The second rule (Art. 15(1), end of first sentence and second sentence)
- Chapter 7: The third rule (Art. 15(2) of the OECD Model)
- Chapter 8: Remuneration of crews of ships or aircraft (Art. 15(3) of the OECD Model)
- Chapter 9: Summary and conclusions
- Chapter 10: Summary and conclusions in Dutch