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Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries

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Release : 1998-07-29
Genre : Business & Economics
Kind : eBook
Book Rating : 536/5 ( reviews)

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Book Synopsis Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries by : Daniel Sandler

Download or read book Tax Treaties and Controlled Foreign Company Legislation:Pushing the Boundaries written by Daniel Sandler. This book was released on 1998-07-29. Available in PDF, EPUB and Kindle. Book excerpt: In-depth analysis of the potential conflict between CFC legislation and tax treaties. The book also evaluates the potential conflict between the CFC legislation, found in European Union countries, and the EC Treaty.

Pushing the Boundaries

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Author :
Release : 1994
Genre : Controlled foreign corporations
Kind : eBook
Book Rating : 323/5 ( reviews)

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Book Synopsis Pushing the Boundaries by : Daniel Sandler

Download or read book Pushing the Boundaries written by Daniel Sandler. This book was released on 1994. Available in PDF, EPUB and Kindle. Book excerpt:

Controlled Foreign Company Legislation

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Author :
Release : 1996
Genre : Business & Economics
Kind : eBook
Book Rating : /5 ( reviews)

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Book Synopsis Controlled Foreign Company Legislation by : Organisation for Economic Co-operation and Development

Download or read book Controlled Foreign Company Legislation written by Organisation for Economic Co-operation and Development. This book was released on 1996. Available in PDF, EPUB and Kindle. Book excerpt: A descriptive report providing factual information on controlled foreign company legislation as of June 1995 in the 14 OECD member countries that operated such regimes.

The Relationship Between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties : New Zealand Case

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Release : 2018
Genre :
Kind : eBook
Book Rating : /5 ( reviews)

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Book Synopsis The Relationship Between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties : New Zealand Case by : B.J. Arnold

Download or read book The Relationship Between Controlled Foreign Corporation Rules and Tax Sparing Provisions in Tax Treaties : New Zealand Case written by B.J. Arnold. This book was released on 2018. Available in PDF, EPUB and Kindle. Book excerpt: This article discusses a recent New Zealand Court of Appeal case involving the relationship between New Zealand's CFC rules and the tax sparing provision in the China-New Zealand Income Tax Treaty (1986). The Court rejected the taxpayer's claim on the basis of a narrow, literal interpretation of the elimination of double taxation article of the treaty.

International Tax Planning and Prevention of Abuse

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Author :
Release : 2008
Genre : Corporations
Kind : eBook
Book Rating : 359/5 ( reviews)

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Book Synopsis International Tax Planning and Prevention of Abuse by : Luc De Broe

Download or read book International Tax Planning and Prevention of Abuse written by Luc De Broe. This book was released on 2008. Available in PDF, EPUB and Kindle. Book excerpt: This study considers how tax authorities attempt to strike down international tax avoidance structures, in particular those involving the use of conduit and base companies set up by third-country residents for purposes of "treaty shopping" and "EC-Directive shopping". The book focuses on the interaction between provisions and judicially developed doctrines of domestic tax law preventing international tax avoidance on the one hand, and norms of international law, in particular tax treaties and rules of Community law, on the other. It also considers treaty-based anti-avoidance measures such as the "beneficial ownership" requirement and "limitation on benefits" provisions. This part of the study compares and analyses the case law of Australia, Austria, Belgium, Canada, the Czech Republic, Finland, France, Germany, India, the Netherlands, Switzerland, the United Kingdom, and the United States.

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