The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention (Series on International Taxation) - Image 1

£92.00

Kluwer Law International The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention (Series on International Taxation)

Name: The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention (Series on International Taxation)
Brand: Kluwer Law International
Price: 92.0 GBP
Availability: InStock

International

Price History & Forecast

Last 69 days • 69 data points (No recent data available)

Historical

Generating forecast...

Price Distribution

Price distribution over 69 days • 1 price levels

Days at Price

Price Analysis

Most common price: £92 (69 days, 100.0%)

Price range: £92 - £92

Price levels: 1 different prices over 69 days

Description

Although rules on the allocation of taxing rights for fees for technical services have been provided for in bilateral tax treaties by African, Asian, and South American countries for decades, it was only in the 2017 update that the UN Model Tax Treaty included Article 12A on the matter, thus suggesting its inclusion in the tax treaty network of its Member States. Consequently, from a cross-border perspective, the interpretation of Article 12A is of great importance for both taxpayers and tax authorities. This book presents the first comprehensive analysis of the scope of technical services in comparison to ordinary (non-technical) services and the differentiation between Article 12A and other allocation rules of the UN Model. The book’s analysis focuses on the interpretation of the concept of technical services by examining the historical evolution of Article 12 of the OECD and UN Models and the systematic context in which it is embedded. Aspects of this analysis examined include the following: the base-erosion principle as justification for establishing source taxing rights without the physical presence of the service provider in the state in which fees for technical services arise; whether the term ‘technical’ is sufficiently defined in the Commentaries to the UN Model or whether it shall be ascribed a different meaning to increase legal certainty for tax authorities and taxpayers; relevance of the OECD Model and its Commentaries as the basis for the UN Model and its Commentaries; rules of precedence concerning the application of Article 12A in relation to the other allocation rules of the UN Model; the connection between royalties and fees for technical services; application of Article 12A UN Model to challenges arising from the digitalized economy; and the allocation of taxing rights for fees for technical services rendered in a third state. Tax treaties of selected African countries are examined, as these countries were the earliest adopters of the concept of fees for technical services into their tax treaty network. The book also provides an overview of literature and jurisprudence on country practices in Brazil, India, and other countries, as well as relevant documents of international organizations. This book provides practitioners, government officials, and academics with a deep understanding of the interpretation and application of Article 12A UN Model. It will prove of great value in preparing for tax treaty negotiations and also in informing and advising enterprises that intend to conduct business in developing countries through the provision of specialized services.

Product Specifications

Brand: Kluwer Law International
Format: hardcover
ASIN: 9403542977
Category: Books > Subjects > Business, Finance & Law > Law > International
Domain: Amazon UK
Release Date: 21 May 2024
Listed Since: 06 July 2024

Barcode

No barcode data available

Kluwer Law International The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model Convention (Series on International Taxation)

Price History & Forecast

Price Distribution

Price Analysis

Description

Product Specifications

Barcode

Similar Products You Might Like

Article 12B UN Model Convention 2021: The UN’s Response to the Tax Challenges Arising From the Digitalization of the Economy

Combating Tax Avoidance in the EU: Harmonization and Cooperation in Direct Taxation (EUCOTAX Series on European Taxation)

Taxpayers' Rights: Theory, Origin and Implementation (Series on International Taxation): 31

Retaliation in the WTO Dispute Settlement System (Global Trade Law Series) (Global Trade Law, 19)

International Taxation: The Indian Perspective (SpringerBriefs in Law)

Dealing with the Fragmented International Legal Environment: WTO, International Tax and Internal Tax Regulations

Tax Sovereignty in the BEPS Era (Series on International Taxation)

International Studies in Taxation: Law and Economics: Law and Economics: 21 (Series on International Taxation,)

International Commercial Tax (Cambridge Tax Law Series)

Wolters Kluwer Fixed Establishments in European VAT - EUCOTAX 39

The Public International Law of Taxation: Text, Cases and Materials

Tax Treaty Case Law Around the Globe - 2011 ( EUCOTAX 34) (Eucotax Series on European Taxation, 34)

Coordination and Cooperation: Tax Policy in the 21st Century: 81 (Series on International Taxation)

International Business Taxation: A Study in the Internationalization of Business Regulation

Liber Amicorum Sven-Olof Lodin: Modern Issues in the Law of International Taxation (SERIES ON INTERNATIONAL TAXATION)

Settlement of Disputes in Tax Treaty Law (EUCOTAX Series on European Taxation Series Set)

Taxation at the European Court of Human Rights

Tax Design Issues Worldwide (International Taxation, 51)

A Multilateral Tax Treaty: Designing an Instrument to Modernise International Tax Law (Series on International Taxation)

International Company Taxation and Tax Planning

International Tax Primer

Wolters Kluwer - Hybrid Financial Instruments Book

Kluwer Law International - Double Non-taxation and Hybrid Entities

Tax Avoidance and the EC Treaty Freedoms: A Study of the Limitations under European Law to the Prevention of Tax Aviodance: 11 (EUCOTAX Series on European Taxation Series Set)