By Peter Harris
Encouraged by way of a postgraduate path the authors have together taught on the collage of Cambridge for the reason that 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax perform) to construct a conceptual framework that not just makes the tax therapy of complicated advertisement transactions comprehensible and obtainable, but in addition demanding situations the present orthodoxy of foreign tax norms. Designed in particular for postgraduate scholars and junior practitioners, it demanding situations the reader to consider tax concerns conceptually and holistically, whereas illustrating the constitution with sensible examples. Senior tax practitioners and lecturers also will locate it priceless as a method of clean their knowing of the fundamentals and the conceptual framework will problem them to imagine extra deeply approximately tax concerns.
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Extra info for International Commercial Tax (Cambridge Tax Law Series)
In this context, each chapter considers the relevant rules in tax treaties, EU Law and, where relevant, underlying domestic law. Within this primary structure, the content of the two chapters is very different. e. Beth. The structure broadly follows that of the OECD Model and so is schedular in nature, dealing with different types of income International Commercial Tax COUNTRY A 5 COUNTRY B Allan rents an office in Country A and pays Beth Beth owns the office and lives in Country B rent payment separately.
This discussion takes account of broad principles that underlie and limit cross-border taxation, including non-discrimination, inter-nation equity, source-country entitlement and reciprocity of withholding tax rates. Comparable principles that underpin EU Law are also considered. The principles are only outlined at this stage; they are used in detail throughout the book in practical examples. Chapter 2 is critical for the purposes of this book because it develops the Base Case upon which much of the remainder of the book is structured.
23 206 280 Canada/US (1980) Art. 5 32 141, 150 China/India (1994) Art. 12 206 China/UK (2005) Art. 13 206 Convention on Mutual Administrative Assistance in Tax Matters (1988) Arts 11–16 455–6, 466 EU Arbitration Convention (1990) 90/436/ EEC Art. 1 Art. 3 Art. 4 Art. 5 Art. 6 Art. 7 Arts. 9–13 462–3 xxxi 466 463 463 463 463 463 463–4 464 xxxii table of treaties Treaty Name Page Reference EU Treaty Art. 3 80 France/UK (1968) Art. 5 125 FEU Treaty Art. 8 Art. 18 Art. 20 Art. 21 Art. 26 Art. 45 Art.