Judicial interpretation of tax treaties : the use of the OECD commentary / Carlo Garbarino.
"Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspecti...
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| Online Access: |
Full Text (via Elgar Law) |
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| Main Author: | |
| Format: | eBook |
| Language: | English |
| Published: |
Cheltenham, UK :
Edward Elgar Publishing Limited,
[2016]
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| Series: | Elgar tax law and practice.
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| Subjects: |
Table of Contents:
- 1. Scope of the treaties
- 2. Residence for treaty purposes
- 3. Definition of permanent establishment
- 4. Business profits and associated enterprises
- 5. Income from immovable property, capital gains, and capital
- 6. Income from equity and from debt
- 7. Royalties
- 8. Income from employment, directors' fees, and students
- 9. Entertainers and sportspersons
- 10. Pensions and government service
- 11. Other income and international transport
- 12. Methods for elimination of double taxation
- 13. Non-discrimination
- 14. Mutual agreement procedure
- 15. Exchange of information and assistance in collection.