Residence of Companies under Tax Treaties and EC Law

Residence of Companies under Tax Treaties and EC Law
This book deals comprehensively with the issues and problems raised by residence of companies for tax purposes.

Why this book?

The book begins with an overview of residence of companies in private international law, with a particular emphasis on general principles of residence and conflict of law rules. It then examines company residence in EC (non-tax) law.

The issue of tax residence of companies is analysed taking into consideration common and civil law countries. A specific chapter is devoted to EC tax law.

Individual country surveys provide an in-depth analysis from a national viewpoint in selected European and North American jurisdictions, Australia and South Africa.

This book is essential reading for all those dealing with issues of taxation of companies engaged in cross-border activities and constitutes a new cornerstone on the subject matter.


Sample excerpt, including table of contents

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

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Guglielmo Maisto


John F. Avery Jones, Niels Bammens, Peter Behrens, Yariv Brauner, Kim Brooks, Reinout de Boer, Nicolas de Boynes, Luc De Broe, Philip De Man, Michael Dirkis, Joachim Englisch, Augusto Fantozzi, Johann Hattingh, Susanne Kalss, Jean Pierre Le Gall, Jean-Frédéric Maraia, Luis A. Martinez Giner, Angelo Nikolakakis, Christiana HJI Panayi, Pasquale Pistone, Jacques Sasseville, Karin Simader, Mario Tenore, Richard Vann, Kees van Raad, Stef van Weeghel, Marcel Widrig and Jan Wouters.

Residence of Companies under Tax Treaties and EC Law
Chapter 1 General Principles on Residence of Companies
Chapter 2 Conflict of Law Rules on Companies in the EU
Chapter 3 EC Law and Residence of Companies
Chapter 4 Corporate Tax Residence in Civil Law Jurisdictions
Chapter 5 Corporate Residence in Common Law: The Origins and Current Issues
Chapter 6 EC Law and Tax Residence of Companies
Chapter 7 "Liable to Tax" and Company Residence under Tax Treaties
Chapter 8 The Expression "by Reason of His Domicile, Residence, Place of Management ..." as Applied to Companies
Chapter 9 The Meaning of "Place of Effective Management"
Chapter 10 Article 4(3) of the OECD Model Convention: An Inconvenient Truth
Chapter 11 Australia
Chapter 12 Austria
Chapter 13 Belgium
Chapter 14 Canada
Chapter 15 France
Chapter 16 Germany
Chapter 17 Italy
Chapter 18 Netherlands
Chapter 19 South Africa
Chapter 20 Spain
Chapter 21 Switzerland
Chapter 22 United Kingdom
Chapter 23 United States
Chapter 24 Round Table: The Issues, Conclusions and Summing-Up

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