Tax Treaty Case Law around the Globe 2021
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This book covers the thirty most important tax treaty cases that were decided around the world in 2020.
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 thirty most important tax treaty cases that were decided around the world in 2020. 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 2021” 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 2021
DOI: https://doi.org/10.59403/2bsht9a
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Austria: Supreme Administrative Court on a Hybrid “Sandwich Structure”
DOI: https://doi.org/10.59403/2bsht9a001
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Australia: Testing the Tax Treaty Residency Tie-Break Rules for Individuals
DOI: https://doi.org/10.59403/2bsht9a002
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France: Concept of Habitual Abode
DOI: https://doi.org/10.59403/2bsht9a003
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France: Limited Tax Liability and Residence
DOI: https://doi.org/10.59403/2bsht9a004
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Italy: Tiziano Ferro v. Agenzia delle entrate – Language (and Conceptual) Discrepancy?
DOI: https://doi.org/10.59403/2bsht9a005
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India: The Dividend Distribution Tax: Entitlement to Treaty Protection?
DOI: https://doi.org/10.59403/2bsht9a006
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Denmark: Did an employee’s Home Office constitute a Permanent Establishment? – Article 5 (1) of the Denmark/Germany Tax Treaty
DOI: https://doi.org/10.59403/2bsht9a007
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Denmark: Taxation of Income from Independent Personal Services? – Article 14 of the Denmark/China Tax Treaty
DOI: https://doi.org/10.59403/2bsht9a008
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France: Concept of the Permanent Establishment
DOI: https://doi.org/10.59403/2bsht9a009
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Turkey: Taxation of Digital Advertising Services Income
DOI: https://doi.org/10.59403/2bsht9a010
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United Kingdom: Royal Bank of Canada v The Commissioners for Her Majesty’s Revenue and Customs (HMRC)
DOI: https://doi.org/10.59403/2bsht9a011
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United Kingdom: Irish Bank Resolution Corporation Ltd v HMRC
DOI: https://doi.org/10.59403/2bsht9a012
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Spain: The Limits to the Interpretation of Tax Treaties in light of later Commentaries to the OECD MC: the Spanish Supreme Court Stryker Case
DOI: https://doi.org/10.59403/2bsht9a013
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Norway: Associated Enterprises (OECD MC Article 9)
DOI: https://doi.org/10.59403/2bsht9a014
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United States: United States Tax Court, The Coca-Cola Company & Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent 155 T.C. No. 10
DOI: https://doi.org/10.59403/2bsht9a015
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Switzerland: Beneficial Ownership and Dynamic Interpretation of Tax Treaties
DOI: https://doi.org/10.59403/2bsht9a016
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Russia: Beneficial Owner/”Actual Owner” and Thin Capitalization
DOI: https://doi.org/10.59403/2bsht9a017
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Spain: The Never-Ending Story of Beneficial Owner: The Colgate Case
DOI: https://doi.org/10.59403/2bsht9a018
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Germany: Taxation of a severance payment
DOI: https://doi.org/10.59403/2bsht9a019
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Switzerland: Distinction between Public and Private Pensions Income under the Swiss and Thailand Tax Treaty
DOI: https://doi.org/10.59403/2bsht9a020
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Poland: Withholding tax on the payment of “match sums” to foreign football federations
DOI: https://doi.org/10.59403/2bsht9a021
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United States: United States Tax Court, Baturin v. US, 153 T.C. No. 10
DOI: https://doi.org/10.59403/2bsht9a022
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Bulgaria: Credit of tax levied not in accordance with the convention – Decision No 409/2020 and of the Supreme Administrative Court
DOI: https://doi.org/10.59403/2bsht9a023
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Portugal: Income from Employment and the Burden of Proof
DOI: https://doi.org/10.59403/2bsht9a024
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Australia: Facing Its Fears in Respect of the Non-Discrimination Article
DOI: https://doi.org/10.59403/2bsht9a025
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Belgium: Increased Attention to Taxpayer Rights in MAPs in Belgian Case Law
DOI: https://doi.org/10.59403/2bsht9a026
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Portugal: Discrimination of Permanent Establishments
DOI: https://doi.org/10.59403/2bsht9a027
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Brazil: Tax Treaty Issues under the Volvo Case
DOI: https://doi.org/10.59403/2bsht9a028
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Germany: Interpretation of the European Arbitration Convention
DOI: https://doi.org/10.59403/2bsht9a029
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Canada: Capital Gains on the Sale of Shares – Alta Energy Luxembourg S.A.R.L. v. The Queen
DOI: https://doi.org/10.59403/2bsht9a030
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Israel: Prosol Holdings S.A. v. Assessor Tel Aviv 5 49525-02-14
DOI: https://doi.org/10.59403/2bsht9a031
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Argentina: Shall the substance over form principle (domestic GAAR) apply to deny treaty benefits arising from Article 22(4) of the OECD MC?
DOI: https://doi.org/10.59403/2bsht9a032
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Georg Kofler, Michael Lang, Alexander Rust, Jeffrey Owens, Pasquale Pistone, Josef Schuch, Karoline Spies, Claus Staringer, Alfred Storck, Peter Essers, Eric Kemmeren, Cihat Öner &Daniel Smit.
