International Tax Policy and Double Tax Treaties: An Introduction to Principles and Application
"This introductory book is written primarily to be used as a teaching text for generic international taxation courses. It has arisen from many years of practice and teaching international taxation to diverse audiences in a variety of countries. The students in those courses have ranged from undergraduates with no practical experience and experienced tax officials with little formal training in the field of international tax to highly qualified tax practitioners." "Regardless of your background or geographical location, international tax law and practice are underpinned by generic principles, which must at least be considered by all countries (if not necessarily applied, for reasons peculiar to a country's political economy at a particular time) when formulating the basis on which a country taxes cross-border transactions and economic events.
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activities allocation anti-avoidance apply arise arm's length Article beneficial owner benefit business profits capital gains capital import CARICOM Agreement Chapter commentary on Art conduit company contracting corporate coun country of residence Country S's tax cross-border deduction definition domestic tax law double tax treaties DTA between Country economic double taxation effective management emphasis added entity example Fiscal foreign source income foreign tax credit head office immovable property income derived income tax interest investment juridical double taxation jurisdiction means ment Netherlands non-resident withholding tax OECD commentary OECD model DTA partnership passive income payments pension permanent establishment place of effective provisions requires resident of Country respect right to tax royalties rules shares sportsperson tax authority tax avoidance tax competition tax haven tax impost tax liability tax paid tax payable tax rate taxable taxed in Country taxing rights taxpayer tion transactions transfer pricing UN model DTA United Kingdom withholding tax worldwide income