Tax Treaty Case Law around the Globe 2019
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This book is a unique publication that discusses the 41 most important tax treaty cases which were decided by judges in 2018 around the globe.
Why this book?
This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 41 most important tax treaty cases which were decided around the world in 2018. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases.
With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2019 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Tax Treaty Case Law around the Globe 2019
DOI: https://doi.org/10.59403/1egfqbv
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Limited Partnerships and Treaty Benefits – Resource Capital Fund IV: Pagone J and Full Federal Court
DOI: https://doi.org/10.59403/1egfqbv001
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Classification of various extraordinary levies as “substantially similar taxes” under DTCs
DOI: https://doi.org/10.59403/1egfqbv002
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Brazil: Taxes Covered: Substantially Similar Taxes
DOI: https://doi.org/10.59403/1egfqbv003
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Poland: Deduction of state taxes paid in the United States
DOI: https://doi.org/10.59403/1egfqbv004
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Netherlands: Place where a company is managed and controlled in order to determine the tax treaty residence
DOI: https://doi.org/10.59403/1egfqbv005
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India: Automated equipment can create a PE and there is no need for human intervention: MasterCard Asia Pacific Pte Ltd
DOI: https://doi.org/10.59403/1egfqbv006
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India: Commission paid for brokerage services is not Fees for Technical services (FTS) – Evolv Clothing case
DOI: https://doi.org/10.59403/1egfqbv007
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Switzerland: Requirements for Foreign Permanent Establishment recognition
DOI: https://doi.org/10.59403/1egfqbv008
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Luxembourg: Conflict of qualification and partnership income: autonomous and common interpretation
DOI: https://doi.org/10.59403/1egfqbv009
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Netherlands: Constructive dividend as a result of interest-free loan in Ireland: extra-territorial application of the Dutch arm’s length principle?
DOI: https://doi.org/10.59403/1egfqbv010
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France: The Deductibility of Wild Withholding Taxes
DOI: https://doi.org/10.59403/1egfqbv011
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Services Permanent Establishment under the Canada-United States Tax Treaty: Wolf v. The Queen, 2018 TCC 84
DOI: https://doi.org/10.59403/1egfqbv012
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OECD Transfer Pricing Guidelines are not law in Malawi
DOI: https://doi.org/10.59403/1egfqbv013
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Hungary: The application of the arm’s length principle regarding the transfer pricing of intra-group loan agreements
DOI: https://doi.org/10.59403/1egfqbv014
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Source Rules in Tax Treaties and Domestic Law: Satyam Case
DOI: https://doi.org/10.59403/1egfqbv015
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Supreme Court of 11 October 2018, case no. 25219
DOI: https://doi.org/10.59403/1egfqbv016
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India: Front end fee does not amount to interest – the case of Société de Promotion et de Participation pour la Coopération Economique
DOI: https://doi.org/10.59403/1egfqbv017
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Bulgaria: Interest, Beneficial Ownership, and Anti-Abuse
DOI: https://doi.org/10.59403/1egfqbv018
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Poland: Beneficial owner requirement in different language versions of the Poland-Sweden Tax Treaty
DOI: https://doi.org/10.59403/1egfqbv019
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Test for meeting the beneficial owner requirement under Art. 10 of DTCs
DOI: https://doi.org/10.59403/1egfqbv020
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Capital Gains on the Sale of Shares: Alta Energy Luxembourg S.A.R.L. v. The Queen
DOI: https://doi.org/10.59403/1egfqbv021
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A Ship “operated in international traffic”? – Article 15(3) of the Nordic Tax Treaty
DOI: https://doi.org/10.59403/1egfqbv022
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South Africa: Where is Employment Exercised when the Employee Renders Services in a Third State
DOI: https://doi.org/10.59403/1egfqbv023
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Belgium: Tax Treatment of the Pension of a Retired School Teacher and the Social Security Benefits for Work Incapacity under the Belgium-Netherlands DTC
DOI: https://doi.org/10.59403/1egfqbv024
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Is a soccer referee a sportsperson? Do all the activities of a company organizing concerts fall within the ambit of Article 17?
DOI: https://doi.org/10.59403/1egfqbv025
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Supreme Court of 7 September 2018, case no. 21865
DOI: https://doi.org/10.59403/1egfqbv026
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Portugal: Is a corporation owning the image rights or economic rights of professional soccer players a “star company”?
DOI: https://doi.org/10.59403/1egfqbv027
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Belgium: Tax Treatment of a Lump Sum Payment for the Exploitation of the Image Rights of a Professional Football Player under the Belgium–Croatia DTC
DOI: https://doi.org/10.59403/1egfqbv028
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Spain: Double International Taxation as a result of an inbound dividend payment
DOI: https://doi.org/10.59403/1egfqbv029
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Discretionary Treaty Benefits
DOI: https://doi.org/10.59403/1egfqbv030
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China: A tax relief for corporate reorganizations was denied to an Italian company (article 24 of the OECD Model)
DOI: https://doi.org/10.59403/1egfqbv031
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The Scope of Exchange of Information in Tax Treaties
DOI: https://doi.org/10.59403/1egfqbv032
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Switzerland: The Narrowing Window for Challenging the Exchange of Information
DOI: https://doi.org/10.59403/1egfqbv033
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Hungary: Registration requirement for advertisement tax purposes through the prism of tax treaty non-discrimination provision
DOI: https://doi.org/10.59403/1egfqbv034
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Michael Lang, Professor and Head of the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
Alexander Rust, Professor at 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.
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).
Peter Essers, Professor of Tax Law at the Fiscal Institute Tilburg of Tilburg University, the Netherlands, Chairman of the Tax Law Department of the Fiscal Institute Tilburg of Tilburg University and member of the Board of the European Tax College.
Eric C.C.M. Kemmeren, Professor of International Tax Law and International Taxation at the Fiscal Institute Tilburg of Tilburg University, 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.
Cihat Öner, Associate Professor at the Fiscal Institute Tilburg of Tilburg University, the Netherlands.
Daniël S. Smit, Professor at the Fiscal Institute Tilburg of Tilburg University, the Netherlands.
