Tax Treaty Case Law around the Globe 2020

Type Book

Series

TTCL Series

Editor(s)

Eric C.C.M. Kemmeren et al.

Date of publication

June 2021

DOI https://doi.org/10.59403/2787p3b

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Tax Treaty Case Law around the Globe 2020

This book is a unique publication that discusses the 32 most important tax treaty cases which were decided by judges in 2019 around the globe.

Why this book?

This book is a unique publication that gives a global overview of international tax disputes in respect of double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the 32 most important tax treaty cases that were decided around the world in 2019. 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 2020 is a valuable reference tool for anyone interested in tax treaty case law, including tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.

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This book is part of the Tax Treaty Case Law around the Globe Series

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Editor(s)

Eric C.C.M. Kemmeren, Professor at the Fiscal Institute Tilburg of Tilburg University, Chairman of the Tax Economics Department of the Fiscal Institute Tilburg of Tilburg University and member of the Board of the European Tax College.

Peter Essers, Professor at the Fiscal Institute Tilburg of Tilburg University, Chairman of the Tax Law Department of the Fiscal Institute Tilburg of Tilburg University and member of the Board of the European Tax College.

Daniël S. Smit, Professor at the Fiscal Institute Tilburg of Tilburg University.

Cihat Öner, Associate Professor at the Fiscal Institute Tilburg of Tilburg University.

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 and Academic Chairman of 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).

Georg Kofler, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).

Karoline Spies, Professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).

Contributor(s)

Ricardo García Antón, Paolo Arginelli, Philip Baker, Martin Berglund, Michael Dirkis, David G. Duff, Kasper Dziurdź, Guilherme Galdino, Esteban Montenegro Guillinta, M.J. Mart van Hulten, Guglielmo Maisto, Joana Mansilha, Cihat Öner, Katerina Pantazatou, Lysandre Papadopoulos, Cees Peters, Marilyne Sadowsky, Luís Eduardo Schoueri, Mirna Solange Screpante, D.P. Sengupta, Daniël S. Smit, A.J.A. Ton Stevens, Stan A. Stevens, Karolina Tetłak, Dinis Tracana, Anne Van de Vijver, Alvaro Villegas Aldazosa, Craig West.
















Tax Treaty Case Law around the Globe 2020: https://doi.org/10.59403/2787p3b
Chapter 1: Peru: Financial Transactions Tax within the Scope of the OECD Model Convention?: https://doi.org/10.59403/2787p3b001
Chapter 2: Australia: Applying the Tax Treaty Residency Tie-Breaker Test: https://doi.org/10.59403/2787p3b002
Chapter 3: Canada: Corporate Residence and the Treaty Tie-Breaker Rule – Landbouwbedrijf Backx B.V. v. The Queen: https://doi.org/10.59403/2787p3b003
Chapter 4: United Kingdom: Fowler v. Revenue & Customs Commissioners: https://doi.org/10.59403/2787p3b004
Chapter 5: India: Splitting Up Contracts into Offshore Supply and Services – The Game Continues: https://doi.org/10.59403/2787p3b005
Chapter 6: Belgium: Can IT Consultants Qualify as Permanent Establishments?: https://doi.org/10.59403/2787p3b006
Chapter 7: Sweden: Construction Permanent Establishment: https://doi.org/10.59403/2787p3b007
Chapter 8: France: Taxing Digital Activities in a Pre-BEPS World: https://doi.org/10.59403/2787p3b008
Chapter 9: France: Permanent Establishment or Independent Establishment?: https://doi.org/10.59403/2787p3b009
Chapter 10: South Africa: The Dangers of Most-Favoured-Nation Clauses: https://doi.org/10.59403/2787p3b010
Chapter 11: The Netherlands: Dutch Dividend Withholding Tax and Most-Favoured-Nation Clause under the Netherlands-South Africa Income Tax Treaty: https://doi.org/10.59403/2787p3b011
Chapter 12: Luxembourg: Qualification of Liquidation Proceeds – Dividend Distributions or Capital Gains?: https://doi.org/10.59403/2787p3b012
Chapter 13: India: Beneficial Ownership in the Context of Capital Gains from Transfers of Shares – The Becton Dickinson case: https://doi.org/10.59403/2787p3b013
Chapter 14: Italy: Applicability of Article 10 of the Italy-Japan Income Tax Treaty to Italian-Source Dividends Paid to a Japanese Pension Fund through Certain US Limited Partnerships: https://doi.org/10.59403/2787p3b014
Chapter 15: Spain: Lease of Industrial Equipment and Supply of Know-How under the Royalty Definition in Article 12 of the OECD Model: https://doi.org/10.59403/2787p3b015
Chapter 16: Poland: Data Centre Renting Fees Are Not Royalties for the Use of Industrial Equipment: https://doi.org/10.59403/2787p3b016
Chapter 17: Poland: Royalties as Compensation for the Unlawful Violation of Design Rights: https://doi.org/10.59403/2787p3b017
Chapter 18: Portugal: Can Management and Coordination Services Be Transfers of Know-How?: https://doi.org/10.59403/2787p3b018
Chapter 19: Brazil: Royalties – Mixed Issues: https://doi.org/10.59403/2787p3b019
Chapter 20: Austria: Article 17 – Racing Days, Training Days and the Weighing of Each Race: https://doi.org/10.59403/2787p3b020
Chapter 21: Canada: The Taxation of Pension Income under Canada’s Tax Treaty with Colombia – Reyes v. Canada: https://doi.org/10.59403/2787p3b021
Chapter 22: Sweden: Payments to and/or from a Certain Pension Considered Either Employment Income or Pension: https://doi.org/10.59403/2787p3b022
Chapter 23: Turkey: Taxation Rights over Independent Personal Services – Procedural Rules for Taxation at Source: https://doi.org/10.59403/2787p3b023
Chapter 24: Italy: Rules Governing the Taxation of Intra-Group Dividends Paid by a German Subsidiary Company to an Italian Parent Company: https://doi.org/10.59403/2787p3b024
Chapter 25: Australia: The Application of the Australia-United States Income Tax Treaty for Relieving Double Taxation and Its Interaction with the Provisions of Domestic Law: https://doi.org/10.59403/2787p3b025
Chapter 26: Belgium: Belgian Foreign Tax Credit in Tax Schemes with Italian Bonds: https://doi.org/10.59403/2787p3b026
Chapter 27: Bolivia: Tax Treaty Benefits Conditional on the Proof of Effective Taxation in the Country of Domicile: https://doi.org/10.59403/2787p3b027
Chapter 28: Luxembourg: Article 26 of the OECD Model – The Meaning of Foreseeable Relevance: https://doi.org/10.59403/2787p3b028
Chapter 29: Switzerland: Article 26 of the OECD Model and the Broad Interpretation of “Foreseeable Relevance”: https://doi.org/10.59403/2787p3b029
Chapter 30: Spain: The Right to Initiate the Mutual Agreement Procedure in a Tax Fraud Case – Challenges Ahead: https://doi.org/10.59403/2787p3b030
Chapter 31: United Kingdom: Application of the Taxpayer for the Disclosure of Documents Exchanged during the Mutual Agreement Procedure: https://doi.org/10.59403/2787p3b031