Taxation of the shipping and air transport industries in domestic law, EU law and tax treaties

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This book provides a detailed and comprehensive study on the taxation of highly transnational industries engaged in the shipping and air transport sectors.
Why this book?
Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties, comprising the proceedings and working documents of an annual seminar held in Milan in November 2016, is a detailed and comprehensive study on the taxation of highly transnational industries engaged in the shipping and air transport sectors. It begins with a comparative analysis of the domestic regulatory and tax regimes of such industries and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union on tonnage taxation systems and VAT regimes.
The book then moves to selected tax treaty issues. In particular, it analyses: (i) the historical background and the proposed changes to articles 8 and 15(3) of the OECD Model Convention; (ii) the recent developments concerning article 8 of the OECD Model Convention and the application of the place of effective management criterion, instead of the residence criterion, as connecting factor; (iii) the most relevant tax treaty issues related to the qualification, allocation and apportionment of income derived by shipping and air transport activities; and (iv) the taxation of the remuneration of crews of ships and aircraft.
Individual country surveys provide an in-depth analysis of the domestic tax regimes and actual tax treaty application and practices of various states, including Australia, Austria, Brazil, Canada, China and Hong Kong, Denmark, Germany, Greece, Italy, Liberia, the Netherlands, Spain, Switzerland and the United Kingdom.
This book presents a unique and detailed insight into the taxation of shipping and air transport activities in an international context and is therefore an essential reference source for international tax students, practitioners and academics.
Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties
DOI: https://doi.org/10.59403/156hvz0
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Chapter 1: Direct Taxation of Air Transport Activities
DOI: https://doi.org/10.59403/156hvz0001
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Chapter 2: Taxation of Shipping Transport Activities (including Tonnage Tax Systems)
DOI: https://doi.org/10.59403/156hvz0002
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Chapter 3: Tonnage Tax and EU law
DOI: https://doi.org/10.59403/156hvz0003
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Chapter 4: Shipping and Air Transport Industry VAT
DOI: https://doi.org/10.59403/156hvz0004
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Chapter 5: Historical Background of Proposed Changes to Articles 8 and 15(3) OECD Model
DOI: https://doi.org/10.59403/156hvz0005
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Chapter 6: Place of Effective Management versus Residence
DOI: https://doi.org/10.59403/156hvz0006
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Chapter 7: Article 8 OECD Model: Time for a Change?
DOI: https://doi.org/10.59403/156hvz0007
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Chapter 8: Issues Relating to Remuneration of Crews of Ships or Aircraft (Article 15(3) OECD Model)
DOI: https://doi.org/10.59403/156hvz0008
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Chapter 9: Australia
DOI: https://doi.org/10.59403/156hvz0009
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Chapter 10: Austria
DOI: https://doi.org/10.59403/156hvz0010
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Chapter 11: Brazil
DOI: https://doi.org/10.59403/156hvz0011
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Chapter 12: Canada
DOI: https://doi.org/10.59403/156hvz0012
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Chapter 13: Mainland China and Hong Kong SAR
DOI: https://doi.org/10.59403/156hvz0013
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Chapter 14: Denmark
DOI: https://doi.org/10.59403/156hvz0014
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Chapter 15: Germany
DOI: https://doi.org/10.59403/156hvz0015
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Chapter 16: Greece
DOI: https://doi.org/10.59403/156hvz0016
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Chapter 17: Italy
DOI: https://doi.org/10.59403/156hvz0017
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Chapter 18: Liberia
DOI: https://doi.org/10.59403/156hvz0018
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Chapter 19: Netherlands
DOI: https://doi.org/10.59403/156hvz0019
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Chapter 20: Spain
DOI: https://doi.org/10.59403/156hvz0020
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Chapter 21: Switzerland
DOI: https://doi.org/10.59403/156hvz0021
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Chapter 22: United Kingdom
DOI: https://doi.org/10.59403/156hvz0022
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Chapter 23: Conclusions from a Business Point of View
DOI: https://doi.org/10.59403/156hvz0023
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Guglielmo Maisto
Haroun Asghar, Raphaël Baeriswyl, Clive M. Baxter, Silvia Boiardi, James R. Border, Micah Burch, Jérôme Bürgisser, Giancarlo Chamma Matarazzo, Elena E.N. Christensen, Theophilus Dekonty Joseph, Michael P. Hansen, Alexander Hemmelrath, Katarina Johannessen, Georg Kofler, Zigurds G. Kronbergs, John J. Lennard, Na Li, Lars Marquardsen, Stefan Maunz, Taco Mooren, Tiago Moreira Vieira Rocha, Ana Pita Grandal, Frank P.G. Pötgens, Isabelle Richelle, Carmen Ruiz Hidalgo, Jacques Sasseville, Ton Stevens, Michail Tegos, Trine Thomsen, Maurits van de Sande, Mees M. Vergouwen, Dennis Weber, Christiane Zöhrer