This book analyses the treatment of income of individuals under Brazilian double taxation conventions. Each article of the Brazilian tax treaties is analysed in order to identify its characteristics, field of application, limits and criteria applied in the identification of taxpayers. The OECD Model Convention is also considered, since it is mirrored in Brazilian conventions. The analysis reveals the unconstitutional nature of Articles 17 and 19 of the Brazilian treaties as they contradict the constitutional principle of isonomy.
This handbook aims at providing an introduction to the law of double taxation conventions.
This book is poised to become one of the key practice resources for tax lawyers, in-house counsel, and policymakers in the coming years.
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital".
This book offers the reader a practical introduction to the law of income and capital tax conventions based on the OECD Convention as well as selected legislation and case law.
"The purpose of this book, then, is to give you an understanding of the concepts that underlie international tax law and double tax treaties by providing an insight into how international tax policy, law and practice operate to ultimately ...
Session Seton Hall J. Sports L. Seton Hall J. Sports & Ent. L. SICAV Skat Ud Skatt Ov. SLT SMAA SNEs SOFA SOT Sp. ... Denmark) Sports Law & Taxation (periodical, Netherlands; formerly: Global Sports Law and Taxation Reports) Sample ...
This second edition of the only publication directly analysing the legal framework and application of LOB clauses in double taxation conventions adds detailed coverage of such major recent developments as the recent tax treaties concluded ...
This book contains an array of material relating to the United States tax treaty network. It serves as a handy desk reference book that provides easy and quick access to...
In order to facilitate the compari son, the text of the 1977 OECD draft is used as reference. Additions and alternatives in any of the other models to this 1977 OECD text are italicized.
... B., and Ouamrane, Y., “Beneficial ownership — a French perspective”, 48 European Taxation 1 (2008), pp. 2-9. Gillies ... Transparency and Beneficial Ownership (in Plato's Cave)”, 64 Bulletinfor International Taxation 4 (2010), pp. 198210 ...