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Book Cover
E-book
Author Garbarino, Carlo, author.

Title Judicial interpretation of tax treaties : the use of the OECD commentary / Carlo Garbarino
Published Cheltenham, UK : Edward Elgar Publishing Limited, [2016]

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Description 1 online resource
Series Elgar tax law and practice series
Elgar tax law and practice.
Contents 1. Scope of the treaties -- 2. Residence for treaty purposes -- 3. Definition of permanent establishment -- 4. Business profits and associated enterprises -- 5. Income from immovable property, capital gains, and capital -- 6. Income from equity and from debt -- 7. Royalties -- 8. Income from employment, directors' fees, and students -- 9. Entertainers and sportspersons -- 10. Pensions and government service -- 11. Other income and international transport -- 12. Methods for elimination of double taxation -- 13. Non-discrimination -- 14. Mutual agreement procedure -- 15. Exchange of information and assistance in collection
Summary "Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation."
Bibliography Includes bibliographical references and index
Notes Online resource; title from title screen (Elgaronline, viewed on May 1, 2018)
Subject Organisation for Economic Co-operation and Development
SUBJECT Organisation for Economic Co-operation and Development fast
Subject Double taxation -- Treaties -- Interpretation and construction
LAW -- Military.
Form Electronic book
ISBN 9781785365881
1785365886