简介
"This work provides a commentary on the OECD Report on Partnerships, which was published in 1999. This report is the first comprehensive analysis on the tax treatment of partnerships and will be the subject of extensive discussion among tax practitioners and academics in the years to come. The OECD Committee has put forward a set ofgeneral principles based on a detailed analysis of practical examples. This book summarises these principles and examines the validity of the premises from which the principles were derived. The critical analysis and in-depth study of practical problems offered here will be of significant value to practitioners and researchers dealingwith this complex subject matter." "The Application of theOECD Model Tax Convention to Partnerships is the result ofextensive research and a number of seminars organised by the Department of Austrian and International Tax Law at the University of Economics and Business Administration inVienna."--BOOK JACKET.
目录
Table Of Contents:
Preface 5(2)
Contents 7(2)
List of Abbreviations 9(2)
List of Symbols 11(2)
OECD Report on Partnerships 13(2)
Methodical Premises of the Report 15(16)
The Relevance of the OECD Report and the Commentary to the OECD Model Tax Convention for the Interpretation of Tax Treaties 15(5)
The Relation between Domestic Law and Tax Treaty Law 20(9)
The Avoidance of Double Taxation and Double Non-Taxation as Object and Purpose of the OECD Model Tax Convention 29(2)
The Entitlement of Partnerships to Treaty Benefits 31(12)
Partnerships as Persons who are Residents of one Contracting State 31(6)
The Relevance of the Tax Treatment in the State of Residence 37(3)
The Relevance of the Tax Treatment in the State of Source 40(3)
The Examples Explaining OECD's Conception on the Entitlement of Partnerships to Treaty Benefits 43(56)
Example 1 43(2)
Example 2 45(3)
Example 3 48(6)
Example 4 54(3)
Example 5 57(2)
Example 6 59(3)
Example 7 62(3)
Example 8 65(3)
Example 9 68(2)
Example 10 70(2)
Example 11 72(2)
Example 12 74(2)
Determination of `Employer' for Purposes of Article 15 76(2)
Example 13 78(4)
Example 14 82(6)
Example 15 88(2)
Example 16 90(3)
Example 17 93(2)
Example 18 95(4)
Conclusion 99
Preface 5(2)
Contents 7(2)
List of Abbreviations 9(2)
List of Symbols 11(2)
OECD Report on Partnerships 13(2)
Methodical Premises of the Report 15(16)
The Relevance of the OECD Report and the Commentary to the OECD Model Tax Convention for the Interpretation of Tax Treaties 15(5)
The Relation between Domestic Law and Tax Treaty Law 20(9)
The Avoidance of Double Taxation and Double Non-Taxation as Object and Purpose of the OECD Model Tax Convention 29(2)
The Entitlement of Partnerships to Treaty Benefits 31(12)
Partnerships as Persons who are Residents of one Contracting State 31(6)
The Relevance of the Tax Treatment in the State of Residence 37(3)
The Relevance of the Tax Treatment in the State of Source 40(3)
The Examples Explaining OECD's Conception on the Entitlement of Partnerships to Treaty Benefits 43(56)
Example 1 43(2)
Example 2 45(3)
Example 3 48(6)
Example 4 54(3)
Example 5 57(2)
Example 6 59(3)
Example 7 62(3)
Example 8 65(3)
Example 9 68(2)
Example 10 70(2)
Example 11 72(2)
Example 12 74(2)
Determination of `Employer' for Purposes of Article 15 76(2)
Example 13 78(4)
Example 14 82(6)
Example 15 88(2)
Example 16 90(3)
Example 17 93(2)
Example 18 95(4)
Conclusion 99
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