Anti-avoidance and Tax Treaty Policies and Practice in the Asian-Pacific Region: Papers Presented at the Joint Conference of the Asian-Pacific Tax and Investment Research Centre and Institute of Policy Studies, Victoria University, Wellington, New Zealand, 9-12 June 1989 |
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Contents
A SURVEY OF JAPANESE STATUTORY | 29 |
TAX TREATIES AND RESIDENCE RULES | 41 |
TAX TREATIES AND RESIDENCE RULES | 69 |
8 other sections not shown
Common terms and phrases
allocation amount apply arbitration arm's length arm's length principle assessment Australian Bank of Thailand basis business in Thailand Canada capital centre of vital competent authority Contracting controlled foreign company corporation correlative adjustment countries Court deduction determined dividends domestic law double tax double taxation enterprise entity exchange of information exemption expenses Fiscal foreign company regime foreign investment fund habitual abode Hong Kong income interests income tax Income Tax Act individual Indonesia Inland Revenue intangibles International Tax Disputes issue Japanese jurisdiction know-how lease legislation Lord Templeman mutual agreement procedure NASSIM ROAD non-resident OECD Model offshore paid paragraph parties patent payments percent permanent home personal and economic profits provisions result royalties shareholders Singapore specific statute subsidiary tax administration tax authorities tax avoidance tax haven tax law tax rate tax treaties taxable taxpayer trade transactions transfer pricing vital interests withholding tax Zealand resident