A Decade of Case Law
A Decade of Case Law
Essays in honour of the 10th anniversary of the Leiden Adv LLM in International Tax Law
- Raffaele Russo, Renata Fontana
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- A Decade of Case Law
Why this book?This book presents and analyses some of the most interesting and debated court decisions of the last decade.The issues analysed in this book include:
- borderline between the definitions of royalties, know-how and services;
- the definition of the term “employer” for treaty purposes;
- the concept of permanent establishment in the context of a
- multinational group;
- non-discrimination issues relating to domestic group consolidation;
- the taxation of partnerships in cross-border situations;
- the concept of place of effective management for treaty purposes;
- the ever-debatable notion of “beneficial owner”; and
- triangular situations.
- Chapter 1: DEL commercial: conduit arrangements and abuse of tax treaties
- Chapter 2: Treaty issues related to the provision of know-how: Comment on a Spanish Supreme Court decision.
- Chapter 3: International hiring-out of labour: Identifying and taxing genuine and abusive scenarios.
- Chapter 4: Multinational enterprises and permanent establishments: The Philip Morris case.
- Chapter 5: Non-discrimination and group consolidation: The Delaware case of the German Bundesfinanzhof and beyond.
- Chapter 6: A case on partnerships: The Rouquier et Rivay decision of the Belgian Supreme Court.
- Chapter 7: Residence: Central management and control versus place of effective management.
- Chapter 8: The Royal Bank of Scotland case: More controversy on the interpretation of the term “beneficial owner”.
- Chapter 9: Triangular cases and double tax relief: A decision of the Netherlands Supreme Court.
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