Tax Treaty Case Law around the Globe 2016
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This book is a unique publication that discusses the 37 most important tax treaty cases which were decided by judges in 2015 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 37 most important tax treaty cases which were decided in 2015 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 2016 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 2016
DOI: https://doi.org/10.59403/3d9zgdm
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Chapter 1: New Zealand: Treaty Interpretation on an Exchange of Information
DOI: https://doi.org/10.59403/3d9zgdm001
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Chapter 2: Argentina: Can a PE Deduct General Administration Expenses?
DOI: https://doi.org/10.59403/3d9zgdm002
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Chapter 3: Spain: Attribution of Free Capital to PEs and Effectiveness of the Authorized OECD Approach
DOI: https://doi.org/10.59403/3d9zgdm003
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Chapter 4: South Africa: Is an Exit Levy a Tax?
DOI: https://doi.org/10.59403/3d9zgdm004
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Chapter 5: Poland: Residence of Individuals
DOI: https://doi.org/10.59403/3d9zgdm005
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Chapter 6: France: Tax-Exempt Entities Are Not Eligible for Tax Treaty Benefits
DOI: https://doi.org/10.59403/3d9zgdm006
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Chapter 7: Portugal: Tax Residence Certification and Entitlement to Compensatory Interest within a Relief at Source System
DOI: https://doi.org/10.59403/3d9zgdm007
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Chapter 8: Italy: Is there a Permanent Establishment?
DOI: https://doi.org/10.59403/3d9zgdm008
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Chapter 9: The Spanish Saga on PEs: The Dell Judgment on “Commissionaires” and “Dependent Subsidiaries”
DOI: https://doi.org/10.59403/3d9zgdm009
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Chapter 10: India: Sale of Airtime and Agency PE
DOI: https://doi.org/10.59403/3d9zgdm010
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Chapter 11: South Africa: Curious Case of the Service PE
DOI: https://doi.org/10.59403/3d9zgdm011
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Chapter 12: Czech Republic: Case 2 Afs 8/2014-174
DOI: https://doi.org/10.59403/3d9zgdm012
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Chapter 13: Italy: Interest-Free Loans and Transfer Pricing
DOI: https://doi.org/10.59403/3d9zgdm013
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Chapter 14: Luxembourg: Profit Adjustments for Interest-Free Loans in Accordance with Article 9
DOI: https://doi.org/10.59403/3d9zgdm014
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Chapter 15: Australia: Pricing Money – The Chevron Case
DOI: https://doi.org/10.59403/3d9zgdm015
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Chapter 16: United States: The Altera Case
DOI: https://doi.org/10.59403/3d9zgdm016
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Chapter 17: Germany: Timing Issues in case of Termination of a Permanent Establishment
DOI: https://doi.org/10.59403/3d9zgdm017
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Chapter 18: Germany: Taxing Right for a Golden Handshake and the Effect of a Mutual Agreement between the Competent Tax Authorities
DOI: https://doi.org/10.59403/3d9zgdm018
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Chapter 19: Austria: Termination Payments
DOI: https://doi.org/10.59403/3d9zgdm019
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Chapter 20: Luxembourg: Application of Article 16 to a “Collège des Commissaires”
DOI: https://doi.org/10.59403/3d9zgdm020
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Chapter 21: Austria: Entertainers under Article 17
DOI: https://doi.org/10.59403/3d9zgdm021
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Chapter 22: Belgium: Article 17 OECD Model Still Entertaining Belgian Courts
DOI: https://doi.org/10.59403/3d9zgdm022
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Chapter 23: Poland: Beneficial Ownership of Interest in the Context of Cash Pooling
DOI: https://doi.org/10.59403/3d9zgdm023
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Chapter 24: Bolivia: Treaty Shopping and Pacta Sunt Servanda
DOI: https://doi.org/10.59403/3d9zgdm024
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Chapter 25: Switzerland: “SWAP Case” and Beneficial Ownership
DOI: https://doi.org/10.59403/3d9zgdm025
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Chapter 26: Argentina: Source-Country Approach: Article 7 versus Article 12
DOI: https://doi.org/10.59403/3d9zgdm026
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Chapter 27: Australia: Royalties and Business Profits in the IT Sector
DOI: https://doi.org/10.59403/3d9zgdm027
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Chapter 28: Netherlands: Exit Taxation of a Substantial Shareholder: Tax Treaty Override?
DOI: https://doi.org/10.59403/3d9zgdm028
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Chapter 29: Denmark: Classification of Foreign Income; Double Non-Taxation? Article 26(2) of the Nordic Tax Treaty
DOI: https://doi.org/10.59403/3d9zgdm029
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Chapter 30: Hungary: Application of Article 23 on Foreign Tax Credit for Lack of Taxable Net Income
DOI: https://doi.org/10.59403/3d9zgdm030
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Chapter 31: United States: The Starr Int’l Case
DOI: https://doi.org/10.59403/3d9zgdm031
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Chapter 32: Netherlands: Triangular Case and Carve-Out Provision under Dutch-Maltese Tax Treaty
DOI: https://doi.org/10.59403/3d9zgdm032
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Chapter 33: Portugal: Non-Discrimination and Access to Domestic Law Incentives for Individuals in the Residence State
DOI: https://doi.org/10.59403/3d9zgdm033
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Chapter 34: Canada: The Canada-US Enhanced Information Exchange Agreement and the Canada-US Tax Treaty
DOI: https://doi.org/10.59403/3d9zgdm034
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Chapter 35: Switzerland: Notion of the Persons Involved in the EoI Procedure
DOI: https://doi.org/10.59403/3d9zgdm035
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Chapter 36: Australia: Enforcing Tax Claims Cross-Border
DOI: https://doi.org/10.59403/3d9zgdm036
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- Eric C.C.M. 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 S. Smit, professor at Fiscal Institute Tilburg of Tilburg University, the Netherlands.
- Peter Essers, professor of tax law at the Fiscal Institute Tilburg of Tilburg University, the Netherlands, and member of the board of the European Tax College.
- Michael Lang, professor 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 of IBFD.
- Alexander Rust, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
Michael Beusch, Yariv Brauner, Luc De Broe, Graeme Cooper, Dániel Deák, David G. Duff, Craig Elliffe, Søren Friis Hansen, Werner Haslehner, Alejandro García Heredia, Daniel Gutmann, Eric C.C.M Kemmeren, Michael Lang, Guglielmo Maisto, Danuše Nerudová, João Félix Pinto Nogueira, Alexander Rust, D.P. Sengupta, Daniel Smit, Karolina Tetlak, Axel A. Verstraeten, Alvaro Villegas Aldazosa, Craig West.
