Tax Treaty Case Law around the Globe 2014
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This book is a unique publication that discusses the 39 most important tax treaty cases which were decided by judges in 2013 around the globe.
Why this book?
This book provides a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 39 most important tax treaty cases that were decided in 2013 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes.
With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2014 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics.
Tax Treaty Case Law around the Globe 2014
DOI: https://doi.org/10.59403/3mak8sp
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Chapter 1: Spain: Are Activities in Vessels, Geographically Concentrated Areas and Director’s Homes PEs?
DOI: https://doi.org/10.59403/3mak8sp001
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Chapter 2: Italy: Italian PE of Slovenian Citizen Who Acted as Tourist Intermediary for a Slovenian Ski Club
DOI: https://doi.org/10.59403/3mak8sp002
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Chapter 3: Sweden: Can a Computer Server Constitute a Permanent Establishment?
DOI: https://doi.org/10.59403/3mak8sp003
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Chapter 4: United Kingdom: Michael Macklin v. Commissioners for Her Majesty’s Revenue and Customs
DOI: https://doi.org/10.59403/3mak8sp004
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Chapter 5: France: Is There Symmetry between State of Taxation and State of Deduction of Expenses?
DOI: https://doi.org/10.59403/3mak8sp005
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Chapter 6: Netherlands: Income from Former Research and Fixed Base and an Origin-Based Alternative
DOI: https://doi.org/10.59403/3mak8sp006
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Chapter 7: Germany: Hidden Profit Distributions under the German-Netherlands Tax Treaty and Transfer Pricing
DOI: https://doi.org/10.59403/3mak8sp007
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Chapter 8: Canada: Judicial Review of Taxpayer’s Request for Competent Authority Assistance under Canada-United States Tax Treaty
DOI: https://doi.org/10.59403/3mak8sp008
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Chapter 9: Denmark: “Arm’s Length” under Article 9(1) of the Denmark-Czech Republic Tax Treaty
DOI: https://doi.org/10.59403/3mak8sp009
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Chapter 10: Czech Republic: Thin Capitalization Rules and Associated Enterprises
DOI: https://doi.org/10.59403/3mak8sp010
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Chapter 11: Netherlands: Sale of Dutch Real Estate by Non-Resident Company, Roll-Over Relief and Recapture: Tax Treaty Override?
DOI: https://doi.org/10.59403/3mak8sp011
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Chapter 12: France: When Does a French Taxpayer Who Transfers Tax Residence to Switzerland Become a Swiss Resident under the Treaty?
DOI: https://doi.org/10.59403/3mak8sp012
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Chapter 13: Italy: The Meaning of “Payment” of Dividend under the OECD Model Revisited
DOI: https://doi.org/10.59403/3mak8sp013
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Chapter 14: Germany: US S Corporation and Income Allocation under Germany-United States Tax Treaty
DOI: https://doi.org/10.59403/3mak8sp014
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Chapter 15: Mexico: Use of DTCs Is Subject to More Requirements Than Demonstration of Fiscal Residence in the Contracting State
DOI: https://doi.org/10.59403/3mak8sp015
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Chapter 16: Kazakhstan: The Oriflame Case – Beneficial Ownership in Sub-Licence Arrangements
DOI: https://doi.org/10.59403/3mak8sp016
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Chapter 17: Turkey: Leasing of Aircraft – Characterization of Leasing Payments as Royalties
DOI: https://doi.org/10.59403/3mak8sp017
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Chapter 18: Spain: Distribution Agreements between Independent Parties, Royalties and Use of Secret Comparables To Fix the Royalty
DOI: https://doi.org/10.59403/3mak8sp018
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Chapter 19: India: The Right Florist Case: Online Advertisement Revenues and the Legal Effect of India’s Position on the OECD Model
DOI: https://doi.org/10.59403/3mak8sp019
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Chapter 20: India: Verizon Communications: Broadband Charges Paid from India Taxable as Royalty
DOI: https://doi.org/10.59403/3mak8sp020
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Chapter 21: India: Siemens Ltd – To Be Taxed as Fees for Technical Services Some Human Intervention Is a Must
DOI: https://doi.org/10.59403/3mak8sp021
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Chapter 22: Austria: The Meaning of the Term “Employer” under Article 15(2)
DOI: https://doi.org/10.59403/3mak8sp022
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Chapter 23: Finland: Taxing Rights on Employee Stock Options under Tax Treaties and the Relevance of the OECD Model Commentary
DOI: https://doi.org/10.59403/3mak8sp023
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Chapter 24: Israel: Relationship between the Employment Article and the Sportsmen Article
DOI: https://doi.org/10.59403/3mak8sp024
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Chapter 25: United States: Allocation of Payments Received for Royalties and Personal Services under Endorsement Contracts
DOI: https://doi.org/10.59403/3mak8sp025
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Chapter 26: Sweden: Is Fictitious Income Covered by Tax Treaties?
DOI: https://doi.org/10.59403/3mak8sp026
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Chapter 27: Belgium: Limitation of Foreign Tax Credit Does Not Infringe Article 23 of the Former Belgium-US Treaty
DOI: https://doi.org/10.59403/3mak8sp027
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Chapter 28: Sweden: The Foreign Tax Credit and Disparities
DOI: https://doi.org/10.59403/3mak8sp028
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Chapter 29: Portugal: PE and Non-Discrimination Regarding Domestic Relief for Double Economic Taxation
DOI: https://doi.org/10.59403/3mak8sp029
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Chapter 30: Russia: Thin Capitalization Rules between Sister Companies under Luxembourg-Russia DTC
DOI: https://doi.org/10.59403/3mak8sp030
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Chapter 31: Switzerland: Group Request under the Switzerland-United States Tax Treaty
DOI: https://doi.org/10.59403/3mak8sp031
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Chapter 32: Luxembourg: The Standard of “Foreseeable Relevance”
DOI: https://doi.org/10.59403/3mak8sp032
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Chapter 33: Liechtenstein: Fishing Expedition
DOI: https://doi.org/10.59403/3mak8sp033
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Chapter 34: Luxembourg: Disclosure of Information Requests in Court
DOI: https://doi.org/10.59403/3mak8sp034
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Chapter 35: Liechtenstein: Legal Protection in Requested State
DOI: https://doi.org/10.59403/3mak8sp035
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Chapter 36: Portugal: Right To Be Notified in Requested State
DOI: https://doi.org/10.59403/3mak8sp036
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Chapter 37: Australia: Use of Information Collected from Cayman Islands
DOI: https://doi.org/10.59403/3mak8sp037
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Chapter 38: Canada: Limitation Period for Secondary Transfer Pricing Adjustments
DOI: https://doi.org/10.59403/3mak8sp038
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Chapter 39: Switzerland: Revised Wording of Article 26 on Mutual Administrative Assistance in Tax Matters
DOI: https://doi.org/10.59403/3mak8sp039
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Contributors
DOI: https://doi.org/10.59403/3mak8sp040
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- Eric Kemmeren, professor of international tax law and international taxation at and chairman of the Tax Economics Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands and member of the board of the European Tax College.
- Daniël Smit, Ph.D. in international tax law and European taxation at the Fiscal Institute Tilburg of Tilburg University, the Netherlands.
- Peter Essers, professor of tax law at and chairman of the Tax Law Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands and member of the board of the European Tax College.
- Michael Lang, professor at and head of the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Jeffrey Owens, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business) and head of the Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU.
- Pasquale Pistone, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business); associate professor at the University of Salerno, Italy and Academic Chairman IBFD.
- Alexander Rust, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Josef Schuch, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Claus Staringer, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Alfred Storck, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
Philip Baker, Tomas Balco, Cédric Ballenegger, Martin Berglund, Stefano Bernasconi, Michael Beusch, Yariv Brauner, José Manuel Calderón Carrero, Graeme Cooper, Tsilly Dagan, Luc De Broe, César Augusto Domínguez Crespo, David Duff, Kasper Dziurdź, Søren Friis Hansen, Marjaana Helminen, Eric C.C.M. Kemmeren, Patrick Knörzer, Michael Lang, Guglielmo Maisto, Alexandre Maitrot de la Motte, Adolfo Martín Jiménez, Danuše Nerudová, João Nogueira, Alexander Rust, Jacques Sasseville, Dikshit Prasad Sengupta, Daniël Smit, Alfred Storck, Danil Vladimirovich Vinnitskiy, Martin Wenz, Billur Yalti, Salome Zimmermann.
