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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

Series:

Volume 12 in the Doctoral Series

Author(s):
Date of publication:
ISBN:

978-90-8722-001-3

Type of publication:

Print Book

Number of pages:

1,056

Terms:

Shipping fees apply. View shipping information

Price:
EUR 150 / USD 190 (VAT excl.)
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Title:

Income from International Private Employment

Series:

Volume 12 in the Doctoral Series

Author(s):
Date of publication:
ISBN:

978-90-8722-001-3

Type of publication:

Online book

Number of pages:

1,056 

Access:

Up to five users. View purchase information

Price:
EUR 150 / USD 190 (VAT excl.)
Order Online book
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Income from International Private Employment

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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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

Author(s)

Frank Pötgens is a tax lawyer practising at De Brauw Blackstone Westbroek, Amsterdam, the Netherlands and teaches International Tax Law at the Erasmus University of Rotterdam.
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