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Taxation of Intercompany Dividends under Tax Treaties and EU Law

This book provides a detailed and comprehensive study on the taxation of cross-border dividend distributions.

 

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Title:

Taxation of Intercompany Dividends under Tax Treaties and EU Law

Series:

Volume 8 in the EC and International Tax Law Series

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

978-90-8722-139-3

Type of publication:

Print Book

Number of pages:

1,050

Terms:

Shipping fees apply. View shipping information

Price:
EUR 120 / USD 160 (VAT excl.)
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Title:

Taxation of Intercompany Dividends under Tax Treaties and EU Law

Series:

Volume 8 in the EC and International Tax Law Series

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

978-90-8722-140-9

Type of publication:

eBook in ePub format

Number of pages:

1,050

Terms:

Please note: Adobe Digital Editions is required

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Price:
EUR 96 / USD 128 (VAT excl.)
Order eBook: ePub
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Title:

Taxation of Intercompany Dividends under Tax Treaties and EU Law

Series:

Volume 8 in the EC and International Tax Law Series

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

978-90-8722-139-3

Type of publication:

Online Book

Number of pages:

1,050

Access:

Up to 5 users. View purchase information

Price:
EUR 120 / USD 160 (VAT excl.)
Order Online Book
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Taxation of Intercompany Dividends under Tax Treaties and EU Law

Why this book?

Taxation of Intercompany Dividends under Tax Treaties and EU Law, comprising the proceedings and working documents of an annual seminar held in Milan on 1 October 2011, is a detailed and comprehensive study on the taxation of cross-border dividend distributions.
 
It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with.
 
Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of “dividends” in the OECD Model Convention and the meaning of the concept of “beneficial owner” as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed.
 
Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration.
 
Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
 
This book is essential reading for all those dealing with cross-border taxation, EU tax law and tax treaty issues.
 

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Series Editor

Guglielmo Maisto


Contributors

John F. Avery Jones, Philip Baker, Peter Blessing, Reinout de Boer, Frederik Boulogne, Maximilian Bowitz, Kim Bronselaer, Paolo de’Capitani di Vimercate, Emilio Cencerrado Millán, Katharina Daxkobler, Philippe Freund, Sebastian Heinrichs, Mark S. Hoose, Philip Kerfs, Katarina Köszeghy, Michael Lang, Koen Lenaerts, Geoffrey Loomer, Alexandre Maitrot de la Motte, Philippe Martin, Angelo Nikolakakis, Elisabeth Pamperl, Kees van Raad, Jacques Sasseville, Kelly Stricklin-Coutinho, C. John Taylor, Peter Wattel, Frans Vaninstendael
 

 

Reviewd by Christiana HJI Panayi

British Tax Review, 2013
 


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