首页 >
税务 >
国际 >
Limitation on Benefits Clauses in Double Taxation Conventions, 2nd Edition

Limitation on Benefits Clauses in Double Taxation Conventions, 2nd Edition

作者： Félix Alberto Vega Borrego
出版商： Kluwer Law International
ISBN: 9789041161352
出版时间 August 2017
规格： Hardback , 336 pages
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

List Price: ￥1,841.40

￥1,786.16 Save ￥55.24 (3%)

或

下载订单表

加入收藏
| 加入比较

描述
大纲

详细
Limitation on Benefits Clauses in Double Taxation Conventions analyses the legal framework and application of limitation on benefits clauses (LOB) in double taxation conventions (DTC), including detailed coverage of major recent developments such as the recent tax treaties concluded between the United States (US) and European Union (EU) Member States, the last version of the US Model Tax Convention (2016), the OECD/G20 project on Base Erosion and Profit Shifting, and relevant new rulings handed down by the European Court of Justice. Upfront planning for international structures is crucial to ensure coverage under bilateral tax treaties. However, as treaty shopping – whereby a third-party national or a corporation sets up a shell company in order to minimize or eliminate income tax – can potentially be facilitated by taking advantage of DTC, companies must carefully scrutinize and comply with requirements found in the LOB clauses in tax treaties. This book studies the specific rules laid down in tax treaties against treaty shopping and, in particular, one type of rule, the LOB.

What’s in this book:

Among the subjects and topics covered are the following:
- definition of the concepts of person and residence provided in the OECD model;
- concept of beneficial owner;
- application of domestic anti-avoidance rules;
- adoption of specific provisions to counter the phenomenon of treaty shopping;
- determination of sufficient nexus with the state of residence or a real business purpose; and
- possible consequences of the incompatibility of LOB clauses with EU law.
How this will help you:

This new edition will continue to provide tax attorneys, tax professionals, and government officials with the perspective needed for effective decision-making in this realm of international taxation. This book deals exclusively with a subject matter of real importance to international tax professionals and their clients. Academics and researchers in taxation will also appreciate the in-depth and up-to-date coverage of this important subject.
Preface

List of Abbreviations

Introduction

Chapter 1 Taxation of Non-Residents and International Tax Planning Through Double Taxation Conventions

Chapter 2 The Subjective Scope of Double Taxation Conventions and Limitation on Benefits Clauses

Chapter 3 Legal Framework and Application of Limitation on Benefits Clauses

Chapter 4 Limitation on Benefits Clauses and European Union Law

Bibliography

Index

你可能需要


The Hong Kong Company Secretary's Handbook: Practice and Procedure (11th Edition): List Price: ￥497.55

￥482.62 Save ￥14.93 (3%)


Hong Kong Tax & Accounting Practical Toolkit (Basic Package): ￥3,161.07


Hong Kong Company Secretary Checklist, 2nd Edition: List Price: ￥1,283.40

￥1,244.90 Save ￥38.50 (3%)


Law of Companies in Hong Kong, 4th Edition (Hardcopy + e-Book): List Price: ￥3,255.00

￥3,157.35 Save ￥97.65 (3%)


Butterworths Hong Kong Discrimination Law Handbook, 4th Edition: List Price: ￥1,395.00

￥1,353.15 Save ￥41.85 (3%)


Sentencing in Hong Kong, 11th Edition: List Price: ￥3,329.40

￥3,229.52 Save ￥99.88 (3%)


Butterworths Hong Kong Company Law (Winding-Up and Miscellaneous Provisions) Handbook, 6th Edition: List Price: ￥2,120.40

￥2,056.79 Save ￥63.61 (3%)


Butterworths Hong Kong Company Law Handbook, 26th Edition: List Price: ￥4,092.00

￥3,969.24 Save ￥122.76 (3%)


Cross-Border Crime in Hong Kong: Extradition, Mutual Assistance & Financial Sanctions, 3rd Edition: List Price: ￥1,934.40

￥1,876.37 Save ￥58.03 (3%)


Clough & Clough on Personal Injuries: List Price: ￥1,395.00

￥1,353.15 Save ￥41.85 (3%)


Hong Kong Personal Insolvency Manual, 3rd Edition: List Price: ￥1,860.00

￥1,804.20 Save ￥55.80 (3%)


Butterworths Hong Kong Conveyancing and Property Law Handbook, 6th Edition: List Price: ￥1,674.00

￥1,623.78 Save ￥50.22 (3%)


A Practical Guide to Resolving Shareholder Disputes, 2nd Edition: List Price: ￥1,674.00

￥1,623.78 Save ￥50.22 (3%)


Tort Law in Hong Kong, 5th Edition (Hardcopy + ebook): List Price: ￥2,325.00

￥2,255.25 Save ￥69.75 (3%)


Company Law in Hong Kong: Practice and Procedure 2023 (Hardcopy + e-Book): List Price: ￥2,974.14

￥2,884.92 Save ￥89.22 (3%)


Company Law in Hong Kong: Insolvency 2023 (Hardcopy + e-Book): List Price: ￥2,643.99

￥2,564.67 Save ￥79.32 (3%)


Hong Kong Company Law, 15th Edition: List Price: ￥457.56

￥443.83 Save ￥13.73 (3%)


Private Equity in Hong Kong and China, 4th Edition: List Price: ￥1,860.00

￥1,804.20 Save ￥55.80 (3%)


Hong Kong Family Court Practice, 4th Edition: List Price: ￥2,511.00

￥2,435.67 Save ￥75.33 (3%)


Brooke's Notary Hong Kong, 3rd Edition: List Price: ￥1,581.00

￥1,533.57 Save ￥47.43 (3%)

“

Ordering from Professional Bookshop is fantastic, quick delivery great products, great customer service Siti L.
This is a great bookstore and have had no problems with them and all my orders have come on time and in good condition. Yang X.
Everything is perfect. Fast delivery. I highly recommend this website to all my friends and colleagues. Thanks Hoi Man L.
So thankful I am receiving all my books, thank you to all for a great service and excellent products Clinton K.
Professional Bookshop is amazing! I've been a loyal customer for over 5 years. Returns are easy to request, book or delivery complaints are taken seriously and the customer service team is friendly and patient. Mick D.
I wanted to informed you that the customer service is excellent. They were so polite and nice. I would continue to buy books from Professional Bookshop. Jingsong C.
Fast and quick service. Easy transaction method, arrived sooner than expected. Excellent packaging and the books received are in perfect condition! Thank you very much! I love the book and its quality. Saori B.
I can order any accounting books from worldwide from Professional Bookshop. Love this website and save my time to search from internet. Lingxiao R.
It is just so easy to find what you are always looking for and sometimes you can even find it up to 80% off what you would in the normal store. Graeme R.
I love shopping on Professional Bookshop! They have a wide range of accounting book with competent prices. Free shipping in Hong Kong is also really handy! Fergus Y.
Professional Bookshop is a great bookstore, I must say. Buying books in Professional Bookshop is so easy, great and reliable. It is highly recommendable. Deborah D.
A great site to shop accounting books and everything and with discountable prices. It’s my first choice whenever i want to shop something. Most trusted site. Zeng Z.
I found the books I needed and at a very low price. I am very happy and will definitely use it in the future Brian W.
I have been using Professional Bookshop for a while now. I am very impressed with customer service and delivery. When I need to have a return it is done very diligently. Olivia L.
Professional Bookshop is my default go to for finding the best prices and reading details of law books before buying. Detailed book description is very helpful. Tracy W.
I've been using Professional Bookshop since 2011 and they actually great, I always received great service and my book arrives on time. Lisa C.

所有书籍

Limitation on Benefits Clauses in Double Taxation Conventions, 2nd Edition

Free delivery Hong Kong?

详细

你可能需要

What Our Customers Say?

所有书籍

Limitation on Benefits Clauses in Double Taxation Conventions, 2nd Edition

Free delivery Hong Kong?

详细

你可能需要

What Our Customers Say?

video title