Tax Treaty Case Law around the Globe 2018
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This unique publication discusses the 35 most important tax treaty cases that were decided around the world in 2017.
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 35 most important tax treaty cases that were decided around the world in 2017. 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 2018 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 2018
DOI: https://doi.org/10.59403/121sv1t
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Chapter 1: Greece: Scope of Application of the Treaty in Case of Income from Unknown Sources
DOI: https://doi.org/10.59403/121sv1t001
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Chapter 2: France: Tax Treaty Abuse as Fraus Legis
DOI: https://doi.org/10.59403/121sv1t002
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Chapter 3: Brazil: Personal Scope in Brazilian Tax Treaties: Treaty Shopping
DOI: https://doi.org/10.59403/121sv1t003
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Chapter 4: Israel: Residence and the Single Tax Principle
DOI: https://doi.org/10.59403/121sv1t004
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Chapter 5: Luxembourg: Dual Residence and Income Qualification of a Lawyer in Hong Kong
DOI: https://doi.org/10.59403/121sv1t005
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Chapter 6: Belgium: Interpretation of Tax Treaties – The Interaction between Domestic Law and Treaty Law
DOI: https://doi.org/10.59403/121sv1t006
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Chapter 7: India: Formula One World Championship Case – Three Days May Be Sufficient to Constitute a Fixed Place PE
DOI: https://doi.org/10.59403/121sv1t007
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Chapter 8: Portugal: Can a Servicer Become an Agent Permanent Establishment?
DOI: https://doi.org/10.59403/121sv1t008
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Chapter 9: Italy: The Shipbuilder’s Subcontractor Case
DOI: https://doi.org/10.59403/121sv1t009
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Chapter 10: Italy: The Fragmented Road Transportation Activity Case
DOI: https://doi.org/10.59403/121sv1t010
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Chapter 11: Greece: Attribution of Profits to PE and Limitations of Deductible Expenses under Domestic Law
DOI: https://doi.org/10.59403/121sv1t011
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Chapter 12: Australia: Setting Interest Rates in Transfer Pricing Disputes
DOI: https://doi.org/10.59403/121sv1t012
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Chapter 13: Germany: Commercial Activities and Losses – The Negative Progression Proviso
DOI: https://doi.org/10.59403/121sv1t013
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Chapter 14: Denmark: Classification of Foreign Income – Article 26(2) of the Nordic Tax Treaty
DOI: https://doi.org/10.59403/121sv1t014
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Chapter 15: Turkey: Taxation of CFC Earnings Before and After the Distribution of Dividends
DOI: https://doi.org/10.59403/121sv1t015
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Chapter 16: Austria: The Economic Employer Concept
DOI: https://doi.org/10.59403/121sv1t016
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Chapter 17: Switzerland: Swiss Federal Supreme Court: Distinction between Income from Employment and Other Income
DOI: https://doi.org/10.59403/121sv1t017
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Chapter 18: Netherlands: Unilateral Changes in Exit Taxation of Annuities and Pensions: Tax Treaty Override?
DOI: https://doi.org/10.59403/121sv1t018
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Chapter 19: Germany: Pensions in Respect of Services Rendered to States
DOI: https://doi.org/10.59403/121sv1t019
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Chapter 20: Portugal: Taxation of Image and Economic Rights of Football Players
DOI: https://doi.org/10.59403/121sv1t020
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Chapter 21: United States: Payments to Graduate Students
DOI: https://doi.org/10.59403/121sv1t021
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Chapter 22: Spain: Aircraft Leasing on a Bareboat Charter Basis – The Meaning of Industrial Equipment in the Royalty Definition
DOI: https://doi.org/10.59403/121sv1t022
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Chapter 23: Poland: Definition of Industrial Equipment and Payments for the Lease of Computer Hardware with Respect to Royalties
DOI: https://doi.org/10.59403/121sv1t023
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Chapter 24: India: Payment for Use of a Standard Facility Does Not Amount to Fees for Technical Services
DOI: https://doi.org/10.59403/121sv1t024
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Chapter 25: Poland: Taxation of Royalties for Computer Software
DOI: https://doi.org/10.59403/121sv1t025
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Chapter 26: Turkey: Payment for the Right to Use of a Software Program Is Royalty
DOI: https://doi.org/10.59403/121sv1t026
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Chapter 27: United Kingdom: R (OAO Aozora GMAC Investment Limited) v. HMRC
DOI: https://doi.org/10.59403/121sv1t027
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Chapter 28: Austria: Severance Payments and Subject-to-Tax Clauses
DOI: https://doi.org/10.59403/121sv1t028
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Chapter 29: New Zealand: Lin v. Commissioner of Inland Revenue (High Court and Court of Appeal of New Zealand)
DOI: https://doi.org/10.59403/121sv1t029
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Chapter 30: France: Loss-Making Companies and the Deductibility of Taxes Paid Abroad
DOI: https://doi.org/10.59403/121sv1t030
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Chapter 31: Argentina: Non-Discrimination – Pirelli Neumáticos SAIC Case
DOI: https://doi.org/10.59403/121sv1t031
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Chapter 32: Netherlands: Non-Discrimination Clause under Dutch/Israeli Tax Treaty and Dutch Group Taxation Regime
DOI: https://doi.org/10.59403/121sv1t032
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Chapter 33: Switzerland: Exchange of Information and “Stolen Data”
DOI: https://doi.org/10.59403/121sv1t033
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Chapter 34: Spain: Taxpayers’ Rights, Corresponding Adjustments and the Right to Initiate MAPs and Arbitration
DOI: https://doi.org/10.59403/121sv1t034
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Chapter 35: Canada: Transfer Pricing Adjustment after a Competent Authority Agreement: Sifto Canada Corp. v. The Queen
DOI: https://doi.org/10.59403/121sv1t035
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- Eric C.C.M. Kemmeren, professor of international tax law and international taxation 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.
- Peter Essers, professor of tax law and Chairman of the Tax Law 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 the Fiscal Institute Tilburg of Tilburg University, the Netherlands.
- Cihat Öner, associate professor at the Fiscal Institute Tilburg of Tilburg University, the Netherlands.
- Michael Lang, professor and Head of the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Jeffrey Owens, professor and Head of the Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- 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).
- 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).
Ricardo García Antón, Paolo Arginelli, Philip Baker, Michael Beusch, Yariv Brauner, Graeme Cooper, Tsilly Dagan, David G. Duff, Craig Elliffe, Peter Essers, Søren Friis Hansen, Guilherme Galdino, Werner Haslehner, Roland Ismer, Eric C.C.M. Kemmeren, Guglielmo Maisto, Christoph Marchgraber, Adolfo Martín Jiménez, João Félix Pinto Nogueira, Cihat Öner, Lysandre Papadopoulos, Katerina Perrou, Cees Peters, Marilyne Sadowsky, Luís Eduardo Schoueri, D.P. Sengupta, Daniël S. Smit, Mirna Solange Screpante, A.J.A. Ton Stevens, Karolina Tetłak, Anne Van de Vijver.
