IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions : How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions

• Author: International Fiscal Association
• Date: 01 Nov 1995
• Publisher: Kluwer Law International
• Original Languages: English
• Book Format: Paperback::64 pages, ePub, Digital Audiobook
• ISBN10: 9041100709
• ISBN13: 9789041100702
• Filename: ifa-how-domestic-anti-avoidance-rules-affect-double-taxation-conventions-how-domestic-anti-avoidance-rules-affect-double-taxation-conventions.pdf
• Dimension: 155.96x 233.93x 3.3mm::99.79g

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Read IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions : How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions. 20 See Art. 1 para. 7 of the 1977 OECD MC Comm., where it was noted that States with domestic anti-avoidance provisions will then wish, in their bilateral double taxation conventions, to preserve the application of provisions of this kind contained in their domestic laws. anti-avoidance rules in domestic law and tax treaties. A convention for the avoidance of double taxation and the prevention of fiscal effect.48 Of the eighty-four jurisdictions that had signed the MLI as of 18 September. New Zealand s tax treaties generally provide for relief from double taxation on all types of income, limit the taxation one country of companies resident in the other and protect companies resident in one country from discriminatory taxation in the other. The treaties generally contain OECD-compliant exchange of information provisions 7.1 Taxpayers may be tempted to abuse the tax laws of a State exploiting the to agree to provisions of bilateraldouble taxationconventions thatwould have the effect irrespective of double taxation conventions, to exploit differences in tax clearly states that domestic anti-avoidance provisions and tax treaties33 are Part IV addresses specific and general anti-avoidance rules, both domestic rules and their relationship to tax treaties as well as anti-avoidance rules contained in tax treaties themselves. Based on this analysis, Part V provides general conclusions. 1 OECD, Draft Double Taxation Convention on Income and Capital, (Paris: OECD, 1963). special anti-abuse rules that can exist in a form of a general anti-avoidance rule, or specific legislative anti-avoidance provisions; or even in the form of developed judicial anti-avoidance doctrines elaborated courts.5 The problem investigated this paper is how domestic anti-avoidance rules affect double taxation conventions. The below PDF | On January 28, 2003 changes were made to the Commentary on Article 1 which deals with the improper use of double tax conventions. Most countries, generally speaking, seem to accept that the domestic anti-avoidance rules? 5.4.6. Estoppel if no specific anti-abuse provision is included in the treaty? 5.4.7. Relevance of 2003 revisions for pre-2003 tax treaties 5.5. Relationship between tax treaties and domestic anti-abuse rules in selected countries 5.5.1. Introduction 5.5.2. Generic types of countries with respect to the The Role of Domestic Law in Tax Treaty Interpretation Prof. Dr. Klaus Vogel Klaus Vogel, 7 December 2001. 2 A. Tax Treaties vs. Domestic Law B. Interpretation of Tax Treaties - Generalities C. Tax Treaties Referring to Domestic Law D. Tax Treaties Complemented Domestic Law. 3 A. Tax Treaties vs. Domestic Law. 4 Tax Treatiesstands short for Double Taxation Conventions (DTCs).As you all know, IFA 1995, How Domestic Anti-Avoidance Rules Affect Double taxation Conventions, Kluwer Law International, The Hague, 1995. IFA 2000, The OECD Model Overview of Major Issues in the Application of Tax Treaties Brian J. Arnold 1. Introduction Over the last few decades, the number of bilateral tax treaties has increased dramatically. How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions:Proceedings of a Seminar Held in Toronto in 1994 During the 48th Congress of the IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions recognized anti-avoidance rules that are applied to tax treaties involves two Buy IFA: How Domestic Anti-Avoidance Rules Affect Double Taxation Conventions International Fiscal Association for $152.99 at Mighty Ape Australia. General Anti-Avoidance Rules and Double Tax. Agreements: A New Zealand Perspective.Craig Elliffe. John Prebble. This Journal Article is brought to you the Faculty of Law at ePublications@bond Domestic and international rules to address double taxation, many of which originated with principles developed in the past the League of Nations in the 1920 s, aim at addressing these overlaps so as to minimise trade distortions and impediments to sustainable economic growth. In contrast, corporations often exploit differences in domestic tax rules and international standards that provide May domestic law anti-avoidance provisions be applied to disregard the tax residence in the other contracting state? The notion of tax based on Art. 2 is relevant also in determining the extent to which one of the contracting states must eliminate double taxation either on the basis of a distributive article or on To the extent that the concept of abuse is a purely domestic one, the question arises how domestic anti-avoidance rules affect double taxation conventions and to what extent one contracting state, for the purpose of taxation, should be prepared to consider the other contracting state's notion of abuse. SEUL IFA CONGRESS SUBJECT 1: ANTI-AVOIDANCE MEASURES OF GENERAL NATURE AND SCOPE-GAAR AND OTHER RULES ARGENTINE REPORT Guillermo O. Teijeiro SUMMARY AND CONCLUSIONS Most countries have either judicial or statutory general anti-avoidance rules (GAAR); Argentina enrols in the second group as GAAR are of statutory nature. to. Tax. B. Deemed Income of Non-Residents under Indian Domestic Law procedure, it may be some time before either Court rules definitively on the under the Indo-Mauritius Double Tax Avoidance Convention (DTAC) (13 April, 2000), amendment could thus affect Vodafone and TelCo notwithstanding that the.

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