Tax Treaty Case Law around the Globe 2013
This book is a unique publication discussing the 36 most important tax treaty cases decided by judges around the globe in 2012.
Why this book?
Tax Treaty Case Law around the Globe 2013 comprises the proceedings of a conference held in Vienna, Austria on 23-25 May 2013. The book provide a unique and comprehensive global overview of international tax disputes on double tax conventions, thereby filling a gap in the area of tax treaty case law. It covers the 36 most important tax treaty cases that were decided around the world in 2012. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties under different regimes.
With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2013 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges and academics.
Tax Treaty Case Law around the Globe 2013
DOI: https://doi.org/10.59403/2kygdfh
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Greece: “Taxes Covered” – Is an extraordinary levy on business profits covered?
DOI: https://doi.org/10.59403/2kygdfh001
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Portugal: Tax treaty case law on personal and substantive scope
DOI: https://doi.org/10.59403/2kygdfh002
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Individual Residence Under the Canada – U.S. Tax Treaty: Trieste v. The Queen
DOI: https://doi.org/10.59403/2kygdfh003
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Slovak Regional Court on a Dutch Holding without sufficient substance
DOI: https://doi.org/10.59403/2kygdfh004
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Dutch Supreme Court 30 November 2012, BNB 2013/54: Determination of the place of effective management of a non-active company
DOI: https://doi.org/10.59403/2kygdfh005
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UK: Yates v Revenue and Customs Commissioners
DOI: https://doi.org/10.59403/2kygdfh006
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Italy: Can agent activities of an Italian Subsidiary constitute a Permanent Establishment of Its Foreign Parent?
DOI: https://doi.org/10.59403/2kygdfh007
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Spain: Permanent establishment – The concept of “fixed place of business” and the concept of “dependent agent”
DOI: https://doi.org/10.59403/2kygdfh008
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Czech Republic: 2 Afs 29/2012-18
DOI: https://doi.org/10.59403/2kygdfh009
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Brazil: Technical services and the application of article 7 under Brazilian treaty practice – A case study
DOI: https://doi.org/10.59403/2kygdfh010
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India: Mediterranean shipping
DOI: https://doi.org/10.59403/2kygdfh011
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Netherlands: Thin capitalization rules are not inconsistent with DTCs and EU Law
DOI: https://doi.org/10.59403/2kygdfh012
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Portugal: Tax treaty case law on the application of Art 12 (royalties)
DOI: https://doi.org/10.59403/2kygdfh013
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Turkey: The Characterisation of Income as Royalty
DOI: https://doi.org/10.59403/2kygdfh014
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Mexico: The application of Article 12 to income derived by the lease of Industrial, Commercial and Scientific Equipment
DOI: https://doi.org/10.59403/2kygdfh015
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Switzerland: Beneficial ownership issues in the light of Art. 10
DOI: https://doi.org/10.59403/2kygdfh016
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Finland: Do Investment Fund Distributions Constitute Dividends?
DOI: https://doi.org/10.59403/2kygdfh017
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Kazakhstan: NWKC Case
DOI: https://doi.org/10.59403/2kygdfh018
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Poland: Judgement of the Supreme Administrative Court of 24 July 2012 (II FSK 2487/11)
DOI: https://doi.org/10.59403/2kygdfh019
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Canada: Capital Gains Realized by an Austrian Private Foundation: Sommerer v. The Queen
DOI: https://doi.org/10.59403/2kygdfh020
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France: The Paupardin Case
DOI: https://doi.org/10.59403/2kygdfh021
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Germany: Interpreting the 183-day rule
DOI: https://doi.org/10.59403/2kygdfh022
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Germany: Pensions vs. Business Income
DOI: https://doi.org/10.59403/2kygdfh023
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India: Mohan Balakrisnan Pookulanagara
DOI: https://doi.org/10.59403/2kygdfh024
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Spain: Taxation of activities related to U2 concerts
DOI: https://doi.org/10.59403/2kygdfh025
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Belgium: Taking into account foreign income for the -calculation of personal tax deduction
DOI: https://doi.org/10.59403/2kygdfh026
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Finland: The Permanent Establishment Non-Discrimination Provision and Transfer of Assets
DOI: https://doi.org/10.59403/2kygdfh027
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Russia: Thin Capitalization Rules and Non-Discrimination Clause in the light of the NaryanmarNefteGaz“ Case
DOI: https://doi.org/10.59403/2kygdfh028
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USA: The United Airlines Flight Attendants’ Saga Continues
DOI: https://doi.org/10.59403/2kygdfh029
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UK: Weiser v Revenue and Customs Commissioners
DOI: https://doi.org/10.59403/2kygdfh030
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Belgium: Territorial allocation of business expenses and -exemption with progression
DOI: https://doi.org/10.59403/2kygdfh031
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UK: Ben Nevis
DOI: https://doi.org/10.59403/2kygdfh032
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List of Authors
DOI: https://doi.org/10.59403/2kygdfh033
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- Michael Lang, professor and head of the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Jeffrey Owens, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business) and head of the Global Tax Policy Center at the Institute for Austrian and International Tax Law, WU.
- Pasquale Pistone, Academic Chairman IBFD, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business) and associate professor at the University of Salerno, Italy.
- Josef Schuch, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Claus Staringer, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Alfred Storck, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- Peter Essers, professor of tax law at the University of Leuven (Belgium) and former member of the board of the European Tax College.
- Eric C.C.M. Kemmeren, professor of international tax law and international taxation and chairman of the Tax Economics Department of the Fiscal Institute Tilburg of Tilburg University, the Netherlands and member of the board of the European Tax College.
- Daniël S. Smit, Ph.D. in international tax law and European taxation at the Fiscal Institute Tilburg of Tilburg University, The Netherlands.
Philip Baker, Tomas Balco, Mateus Calicchio Barbosa, Michael Beusch, Renata Blahova, Yariv Brauner, David Duff, José Almeida Fernandes, Malcolm Gammie, Marjaana Helminen, Eric C.C.M. Kemmeren, Hanna Litwińczuk, Philippe Martin, Danuše Nerudová, Katerina Perrou, Pasquale Pistone, César Alejandro Ruiz Jiménez, Alexander Rust, Jacques Sasseville, Luís Eduardo Schoueri, D.P. Sengupta, Daniël Smit, Maria Teresa Soler Roch, Edoardo Traversa, Billur Yaltı, Danil V. Vinnitskiy, Gaëtan Zeyen.
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