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