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The Meaning of “Enterprise”, “Business” and “Business Profits” under Tax Treaties and EU Tax Law

An in-depth analysis of the meaning of these three concepts in relevant tax treaties and law. Essential reading for those dealing with issues of taxation of enterprises engaged in cross-border activities.
 
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Title:

The Meaning of “Enterprise”, “Business” and “Business Profits” under Tax Treaties and EU Tax Law

Series:

Volume 7 in the EC and International Tax Law Series

Editor(s):
Guglielmo Maisto
Date of publication:
ISBN:

978-90-8722-101-0

Type of publication:

Print Book

Number of pages:

642

Terms:

Shipping fees apply. View shipping information

Price:
EUR 110 / USD 145 (VAT excl.)
Order Print
tab_1
Title:

The Meaning of “Enterprise”, “Business” and “Business Profits” under Tax Treaties and EU Tax Law

Series:

Volume 7 in the EC and International Tax Law Series

Editor(s):
Guglielmo Maisto
Date of publication:
ISBN:

978-90-8722-101-0

Type of publication:

Online book

Number of pages:

642

Access:

Up to five users. View purchase information

Price:
EUR 110 / USD 145 (VAT excl.)
Order Online book
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The Meaning of “Enterprise”, “Business” and “Business Profits” under Tax Treaties and EU Tax Law

Why this book?

The Meaning of “Enterprise”, “Business” and “Business Profits” under Tax Treaties and EU Tax Law, comprising the proceedings and working documents of an annual seminar held in Milan in November 2010, provides an in-depth analysis of the meaning of these three essential concepts in relevant tax treaties and law.

The analysis starts from an EU tax law perspective, with a particular emphasis on the European Directives. The above concepts are then considered from domestic tax law viewpoints.
 
The book then moves to tax treaty law. Most notably, an examination of the history and interpretation of the concepts of “enterprise”, “business” and “business profits” is presented, starting from the works of the League of Nations to the current OECD Model Tax Convention.
 
Next, specific tax treaty issues are considered. In particular, the controversial issues concerning the interpretation of the notions of “enterprise” and “enterprise of a Contracting State” are discussed. Also, the concepts of “profits” and “business profits” are thoroughly reviewed. The concept of “enterprise” in the context of the non-discrimination clause laid down by Art. 24 of the OECD Model Tax Convention is then examined.
 
Individual country surveys provide an in-depth analysis of the aforementioned concepts and issues from a national viewpoint in selected European and North American jurisdictions, as well as in Australia and Japan.
 
The book concludes with a round-table discussion among some of the most renowned international tax scholars on the desirability to change the OECD Model Tax Convention and its Commentaries.
 
This book is essential reading for all those dealing with issues of taxation of enterprises engaged in cross-border activities and can be considered a new cornerstone in the subject matter.
 

Downloads

 

This book is part of the EC and International Tax Law Series

Downloads

 

Main contents

 

  • Part one: EU tax law
  • Part two: Tax taw
  • Part three: Special issues in tax treaty law
  • Part four: Country reports - Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Luxembourg, Netherlands, United Kingdom, United States
  • Part five: Round-table discussion on the desirability to change the OECD Model Convention and its Commentaries
     

Contributors

Asatsuma Akiyuki, Rachael Arning, Elke Aumayr, Francesco Avella, John Avery Jones, Yariv Brauner, Kim Brooks, Ellen Cassaer, Allison Christians, Graeme S. Cooper, Luc De Broe, Augusto Fantozzi, Anna Gunn, Sebastian Heinrichs, Katarina Köszeghy, Michael Lang, Nicolas Message, Andrea Parolini, Pasquale Pistone, Kees van Raad, Alexander Rust, Jacques Sasseville, and Katrien Willoqué

 

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