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Tuesday, July 21, 2020 | History

4 edition of application of the OECD model tax convention to partnerships found in the catalog.

application of the OECD model tax convention to partnerships

a critical analysis of the report prepared by the OECD Committee on Fiscal Affairs

by Lang, Michael Dr.

  • 297 Want to read
  • 31 Currently reading

Published by Kluwer Law International in Boston, MA .
Written in English

    Subjects:
  • Partnership -- Taxation,
  • Double taxation

  • Edition Notes

    Statementby Michael Lang.
    Classifications
    LC ClassificationsK4543.5 .L36 2000
    The Physical Object
    Paginationp. cm.
    ID Numbers
    Open LibraryOL6786832M
    ISBN 109041197915
    LC Control Number00042662

    The Application of the OECD model tax convention to partnerships Imprint Paris, France: Organisation for Economic Co-operation and Development ; Washington, D.C.: OECD Publications and Information Centre [distributor], c The OECD Model Convention, as amended in , includes a provision that would allow the sharing of information obtained under article 26 with persons charged with the oversight of the persons.

    OECD: Report on "The application of the OECD Model Tax Convention to Partnerships" and the interpretation of tax treaties. Publication date: 01 Jul 00 | Source: EUROPEAN TAXATION Issue: No 7. Pages: pp Abstract: The authors take a critical look at the proposals made by the OECD Fiscal Committee in its recent partnerhsip report. 2 See for instance OECD, The Application of the OECD Model Tax Convention to Partnerships, Issues in International Taxation 6 (). 3 See Ward D et al., The Interpretation of Income Tax Treaties with Particular Reference to the Commentaries on the OECD Model () pp with further references. 4 ATO TR /13, para

    See, e.g., OECD, OECD Model Tax Convention: Revised Proposals Concerning the Interpretation and Application of Article 5 (Permanent Establishment), (); OECD, Action Plan on Base Erosion and. Unfortunately, the OECD has not expressly dealt with the application of the Model Tax Convention to trusts. This lack of a clear rule can lead to several problems regarding the applicability of double tax treaties especially when civil law countries, such as Malta, are involved.


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Application of the OECD model tax convention to partnerships by Lang, Michael Dr. Download PDF EPUB FB2

The Application of the OECD Model Tax Convention to Partnerships The application of tax treaties to cases involving partnerships raises a number of complex issues.

When is a partnership entitled to the benefits of a tax convention. The Application of the Oecd Model Tax Convention To Partnerships, A Critical Analysis of the Report Prepared By the Oecd Committee on Fiscal Affairs 1st Edition.

The Application of the Oecd Model Tax Convention To Partnerships, A Critical Analysis of the Report Prepared By the Oecd Committee on Fiscal Affairs. 1st by: 2. Issues in International Taxation The Application of the Oecd Model Tax Convention to Partnerships (Issues in International Taxation, 6) [Organisation for Economic Co-operation and Development, oecd] on *FREE* shipping on qualifying offers.

The Application of the OECD Model Tax Convention to Partnerships is the result of extensive research and a number of seminars organised by the Department of Austrian and International Tax Law at the University of Economics and Business Administration in Vienna.

"synopsis" may belong to another edition of this Range: $ - $ The Application of the Oecd Model Tax Convention to Partnerships. The application of tax treaties to cases involving partnerships raises a number of complex issues.

The Application of the OECD Model Tax Convention to Partnerships. This report addresses the issue of the application of tax treaties to cases involving partnerships in detail and focuses on specific factual examples.

This site is powered by KeepeekLogiciel Photothèque Professionnel for business. THE APPLICATION OF THE OECD MODEL TAX CONVENTION TO PARTNERSHIPS I. INTRODUCTION I.1 Background 1.

Inthe Committee formed a Working Group to study the application of the Model Tax Convention to partnerships, trusts, and other non-corporate entities. This first report by the Working Group, which the Committee adopted on 20 JanuaryfocusesFile Size: 1MB.

The Application of the OECD Model Tax Convention to Partnerships Model Tax Convention on Income and on Capital (Full Version) This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital.

The report by the OECD on the application of the OECD Model Tax Convention to partnerships clarifies some of the issues arising regarding the status of partnership in an international context.

This article examines various issues considered in the report, such as the entitlement to treaty protection, the elimination of double taxation, and. application of the Convention to partnerships, trusts and other non-corporate entities.

That first report – the Partnerships Report – dealt with the application of the OECD Model to partnerships. Further reports are anticipated on trusts and other entities, through there are some principles discussed in the Partnerships Report which are relevant to all these Size: KB.

Issues in International Taxation The Application of the OECD Model Tax Convention to Partnerships by OECD - Books on Google Play Issues in International Taxation The Application of the OECD Model Author: OECD.

Application of the OECD Model Tax Convention to Partnerships”, 1 the conclusions of which have been incorporated below and in the Commentary on various other provisions of the Model Tax Convention.

As discussed in that report, a main source of difficulties is the fact that some. (source: Nielsen Book Data) Summary This work provides a critical commentary on the OECD Report on Partnerships, which was published in This report is the first comprehensive analysis of the tax treatment of partnerships and potentially, the subject of extensive discussion among tax practitioners and academics in the years to come.

This publication is the tenth edition of the condensed version of the OECD Model Tax Convention on Income and on Capital. This shorter version contains the articles and commentaries of the Model Tax Convention on Income and Capital as it read on 21 Novemberbut without the historical notes and the background reports that are included in the full version.

"The Application of the OECD Model Tax Convention to Partnerships is the result of extensive research and a number of seminars organised by the Department of Austrian and International Tax Law at the University of Economics and Business Administration in Vienna."--BOOK JACKET.

99 p.: ill. ; 24 cm. Partnership -- Taxation. Double taxation. The Application of the OECD Model Tax Convention to Partnerships: Issues in International Taxation No.

6 The full text article is not available for purchase. The publisher only permits individual articles to be downloaded by subscribers. Application of the OECD Model Tax Convention to Partnerships”.3 That Report therefore, provides guidance and examples on how the provision should be interpreted and applied in various situations.

The application of the OECD model tax convention to partnerships - Organisation for Economic Co-operation and Development - Google Boeken The application of tax treaties to cases involving partnerships raises a number of complex issues.

When is a partnership entitled to. OECD Report: The application of the OECD Model Tax Convention to partnerships () (E) The granting of treaty benefits with respect to the income of collective investment vehicles Materials_deel1 - 05 book Page ix Tuesday, PM. Buy The Application of the OECD Model Tax Convention to Partnerships: A Critical Analysis of the Report Prepared by the OECD Committee on Fiscal Affairs, by Michael Lang, ISBNpublished by Kluwer Law International fromthe World's Legal Bookshop.

Shipping in the UK is free. Competitive shipping rates world-wide. Lang, Michael, The Application of the OECD Model Tax Convention to Partnerships – A Critical Analysis of the Report Prepared by the OECD Committee on Fiscal Affairs (Kluwer Law International ). Lenger, Barbara, ‘Subject-to-Tax Provisions and The Taxation of Employment Income in DTC Law’ in: Daniela Hohenwarter and Vanessa Metzler (eds.Application of the OECD model tax convention to partnerships.

Paris: Organisation for Economic Co-operation and Development, © (OCoLC) Online version: Application of the OECD model tax convention to partnerships. Paris: Organisation for Economic Co-operation and Development, © (OCoLC) Material Type: Internet resource.OECD has introduced a number of new provisions regarding the entitlement to tax treaties into its Model Convention as part of the BEPS Project.

This book analyses several crucial areas concerning the entitlement to tax treaties. The topics covered include: • The application of the principal purpose test, limitation on benefits clauses and the.