Papers from the conference source versus residence the allocation of taxing rights in tax treaty law problems arising from the existing tax treaty provisions and possible alternatives isbn 9789041127631 9041127631. The oecd model tax treaty other model conventions and the bilateral treaties drafted in accordance with these models allocate the taxing rights between the state of source and the state of residence the source rules for income taxation are determined by articles 6 through 21 of the oecd model convention. Source versus residence problems arising from the allocation of taxing rights in tax treaty law and. The book analyses the allocation rules of the oecd model tax convention and its equivalents in bilateral tax treaties the contributors examine the justification for these rules as well as their scope and highlight the most relevant interpretation and attendant application problems in addition they suggest how such rules should be modified and examine possible alternatives. Source versus residence problems arising from the allocation of taxing rights in tax treaty law and possible alternatives edited by michael lang pasquale pistone josef schuch claus staringer austin boston chicago new york the netherlands law business
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