Model Tax Convention on Income and on Capital: Condensed by Organization for Economic Cooperation and Development

By Organization for Economic Cooperation and Development

###############################################################################################################################################################################################################################################################

Show description

Read Online or Download Model Tax Convention on Income and on Capital: Condensed Version 2010 PDF

Similar specialties books

The JCT Standard Building Contract 2011

Books approximately building contracts are typically dense and wordy, yet what so much architects, volume surveyors, undertaking managers, developers and employers are trying to find is an simply navigable, easy consultant to utilizing a freelance, written in simple language. The JCT general development agreement 2011 is an simple publication a few advanced and widely used agreement.

Laryngology

Laryngology is a compact but entire source at the administration of problems of voice, airway, and swallowing. It discusses the newest options in laryngeal documentation, key rules in administration of laryngeal issues, end result measures and quality-of-life overview, and evolving applied sciences in laryngology.

Flesh and bones of surgery

This identify is directed basically in the direction of well-being care pros outdoors of the us. It provides a concise and available account of this key topic within the undergraduate clinical curriculum. It covers all of the key ideas scientific scholars want without gaps. it may be used both as an creation to a subject matter, or as a revision relief.

Extra info for Model Tax Convention on Income and on Capital: Condensed Version 2010

Sample text

For purposes of this paragraph, the term “collective investment vehicle” means, in the case of [State A], a [ ] and, in the case of [State B], a [ ], as well as any other investment fund, arrangement or entity established in either Contracting State which the competent authorities of the Contracting States agree to regard as a collective investment vehicle for purposes of this paragraph. 18 However, in negotiating new treaties or amendments to existing treaties, the Contracting States would not be restricted to clarifying the results of the application of other treaty provisions to CIVs, but could vary those results to the extent necessary to achieve policy objectives.

Where, for instance, the State of source treats a domestic partnership as fiscally transparent and therefore taxes the partners on their share of the income of the partnership, a partner that is resident of a State that taxes partnerships as companies would not be able to claim the benefits of the Convention between the two States with respect to the share of the partnership’s income that the State of source taxes in his hands since that income, though allocated to the person claiming the benefits of the Convention under the laws of the State of source, is not similarly allocated for purposes of determining the liability to tax on that item of income in the State of residence of that person.

11 Whether a CIV is a “resident” of a Contracting State depends not on its legal form (as long as it qualifies as a person) but on its tax treatment in the State in which it is established. Although a consistent goal of domestic CIV regimes is to ensure that there is only one level of tax, at either the CIV or the investor level, there are a number of different ways in which States achieve that goal. In some States, the holders of interests in the CIV are liable to tax on the income received by the CIV, rather than the CIV itself being liable to tax on such income.

Download PDF sample

Rated 4.43 of 5 – based on 26 votes