Tax Treaty Case Law around the Globe 2015
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This book is a unique publication that discusses the 43 most important tax treaty cases which were decided by judges around the globe in 2014.
Why this book?
This book provides 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 43 most important tax treaty cases that were decided in 2014 around the world. The systematic structure of each case allows easy and efficient comparison of the varying application and interpretation of tax treaties in different regimes.
With the continuously increasing importance of tax treaties, Tax Treaty Case Law around the Globe 2015 is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational enterprises, policymakers, tax administrators, judges and academics.
Tax Treaty Case Law around the Globe 2015
DOI: https://doi.org/10.59403/3rv54kq
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Australia: Hybrid entities – Resource Capital Fund III LP Case
DOI: https://doi.org/10.59403/3rv54kq001
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United Kingdom: George Anson vs. HMRC
DOI: https://doi.org/10.59403/3rv54kq002
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Argentina: Petrobras Case: Is Argentinian Minimum Presumed Income Tax covered in Tax Treaties?
DOI: https://doi.org/10.59403/3rv54kq003
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Finland: Is the Estonian Corporate Tax Covered by Article 2 and Creditable under Article 23?
DOI: https://doi.org/10.59403/3rv54kq004
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Canada: Conrad Black vs. the Queen – Dual Residence and the Remittance Basis of Taxation
DOI: https://doi.org/10.59403/3rv54kq005
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Luxembourg: The Effect of a Tax Treaty Tie-breaker for Dual Residents
DOI: https://doi.org/10.59403/3rv54kq006
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Norway: GE Healthcare Case – Hybrid Entity
DOI: https://doi.org/10.59403/3rv54kq007
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South Korea: The Application of Tax Treaties to Partnerships and Hybrid Entities
DOI: https://doi.org/10.59403/3rv54kq008
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Brazil: CFC Rules and Tax Treaties in Brazil: A Case for Article 7
DOI: https://doi.org/10.59403/3rv54kq009
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France: Minister vs. Société Bayerische Hypo und Vereinsbank
DOI: https://doi.org/10.59403/3rv54kq010
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France: Société DGFP Zeta
DOI: https://doi.org/10.59403/3rv54kq011
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Austria: Constitutional Review of Tax Treaties
DOI: https://doi.org/10.59403/3rv54kq012
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Poland: Has the Non-resident Company as a Shareholder of the Polish SKA a Permanent Establishment in Poland?
DOI: https://doi.org/10.59403/3rv54kq013
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Bolivia: Total E&P Bolivie Sucursal Bolivia, a PE of two French Companies at the Same Time
DOI: https://doi.org/10.59403/3rv54kq014
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Italy: No Permanent Establishment for Toll Manufacturers without Participation in Strategic Decision-Making
DOI: https://doi.org/10.59403/3rv54kq015
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Spain: The Spanish Position on the Concept of PE: “Complex Operative Settlements” and “Industrial Dependent Agents” as PEs
DOI: https://doi.org/10.59403/3rv54kq016
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Netherlands: Taxation of Notional Amount (Box 3) Rather than Paid Dividend: No Tax Treaty Override
DOI: https://doi.org/10.59403/3rv54kq017
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Denmark: Capital Gains; Permanent Establishment; Article 7 of the Denmark-Germany Tax Treaty
DOI: https://doi.org/10.59403/3rv54kq018
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Norway: Dividend; Article 10 of the Nordic tax treaty
DOI: https://doi.org/10.59403/3rv54kq019
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Argentina: Treaty Entitlement and Abuse: Argentina’s Molinos Case
DOI: https://doi.org/10.59403/3rv54kq020
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Australia: Royalties – Task Technology and Seven Network Cases
DOI: https://doi.org/10.59403/3rv54kq021
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Poland: The Legitimacy of Double Tax Relief for Dividends Prior to Directive 2014/86/EU: Poland’s 2014 Supreme Administrative Court Judgment (II FSK 187/12)
DOI: https://doi.org/10.59403/3rv54kq022
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Canada: McKesson Canada Corporation vs. The Queen – Judges are Human
DOI: https://doi.org/10.59403/3rv54kq023
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Finland: KHO 2014/2117 (119) – Does Article 9 Allow Reclassification of Hybrid Debt as Equity in Finland?
DOI: https://doi.org/10.59403/3rv54kq024
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India: Whether Transactions between two Resident Companies are within the Scope of India’s Transfer Pricing Regulation: the Case of Vodafone (India) Services Pvt Ltd
DOI: https://doi.org/10.59403/3rv54kq025
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Spain: Article 15 OECD Model Convention, Stock Options and Inpatriate Tax Regimes: Judgment of “Tribunal Superior de Justicia” of Madrid of 12 March 2014
DOI: https://doi.org/10.59403/3rv54kq026
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Russia: Withholding Tax on Agency Fees under the Russia-Germany Tax Treaty (Articles 14, 15 and 21)
DOI: https://doi.org/10.59403/3rv54kq027
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Belgium: Employment Income from Directors – Physical Presence in the Source State
DOI: https://doi.org/10.59403/3rv54kq028
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Belgium: Allocation of Employment Income from Sportspersons
DOI: https://doi.org/10.59403/3rv54kq029
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United Kingdom: Michael Macklin vs. HMRC
DOI: https://doi.org/10.59403/3rv54kq030
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United States: The Saving Clause, Green Card Holders and Article 19
DOI: https://doi.org/10.59403/3rv54kq031
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Belgium: Constitutionality of Interest Credit in Belgium-Australia DTC
DOI: https://doi.org/10.59403/3rv54kq032
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Netherlands: Dutch Supreme Court 31 January 2014, BNB 2014/77: Worldwide Taxation of Non-Resident Taxpayers for Purposes of Calculating the Average Tax Rate: Tax Treaty Override?
DOI: https://doi.org/10.59403/3rv54kq033
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Switzerland: The Revised Provisions on Administrative Assistance in Swiss Double Taxation Agreements: Limitations Arising from National Law
DOI: https://doi.org/10.59403/3rv54kq034
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Switzerland: Substantiation of a request under the France-Switzerland Tax Treaty
DOI: https://doi.org/10.59403/3rv54kq035
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South Africa: Retrospectivity of Treaty Clauses Regarding Assistance in the Collection of Taxes and the Preservation of Assets
DOI: https://doi.org/10.59403/3rv54kq036
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India: Credit for Taxes “Paid” as opposed to “payable” – the Case of Vijay Electricals Ltd
DOI: https://doi.org/10.59403/3rv54kq037
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India: Is a Competent Authority Determination on the Existence of a PE in the Source State Determinative? – The Case of eFunds Inc
DOI: https://doi.org/10.59403/3rv54kq038
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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, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business), associate professor at the University of Salerno, Italy, and Academic Chairman IBFD.
- Alexander Rust, professor at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
- 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 at 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, PhD in international tax law and European taxation at the Fiscal Institute Tilburg of Tilburg University, The Netherlands.
Brian J. Arnold, Philip Baker, Mateus Calicchio Barbosa, Stefano Bernasconi, Michael Beusch, Emmanuelle Cortot Boucher, Yariv Brauner, Hyejung Byun, Eivind Furuseth, Søren Friis Hansen, Werner Haslehner, Marjaana Helminen, Adolfo Martín Jiménez, Eric C.C.M. Kemmeren, Beat König, Hanna Litwińczuk, Pasquale Pistone, Jennifer Roeleveld, Alexander Rust, Luis Eduardo Schoueri, D.P. Sengupta, Daniël Smit, Edoardo Traversa, Richard Vann, Axel Verstr
