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Tax Treaty Residence of Entities

Original price was: $137.75.Current price is: $48.21.

It is of great importance to be able to determine who or what is considered 'resident' within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the 'legalistic' requirements for corporate residence. In this study of the OECD Model Tax Convention -the basis for most tax treaties -the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term 'resident' that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on 'place of effective management' and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of 'resident', the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author's guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.Product details Simultaneous Publisher: Kluwer Law International (September 13, 2019) Publication Date: September 13, 2019

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Eligibility for Returns and Exchanges

We accept returns and exchanges within 30 days from the date your order is delivered. Items must be unused, in the original condition, and accompanied by the original packaging and receipt or proof of purchase.

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To initiate a return or exchange, please follow these steps:

Contact our customer support at contact@zetlly.com with your order number and reason for return or exchange.
Our team will respond within 24 hours to provide detailed instructions, including the specific Return Address for your shipment.
Package your item securely and include all original packaging and proof of purchase.

Return shipments should be sent to: Blanq LLC 1201 South Hope Street Apt 2413, Los Angeles, CA 90015, USA

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Items must be returned in their original condition, unworn, undamaged, and complete with all original packaging and documentation.
Items returned without prior authorization or not meeting the above conditions may not qualify for a refund or exchange.

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Customers are responsible for return shipping costs unless the return is due to our error or a defective product. We recommend using a trackable shipping service to ensure your return reaches us safely.

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It is of great importance to be able to determine who or what is considered ‘resident’ within the meaning of tax treaty provisions. However, the concept of residence has never been fundamentally adjusted to current circumstances in which technological developments make it possible for corporations to explore the wide gap between their actual business operations and the ‘legalistic’ requirements for corporate residence. In this study of the OECD Model Tax Convention -the basis for most tax treaties -the author develops a clear understanding of the content of the residence concept as regards entities and proposes solutions to current problems, finishing with his own thoroughgoing definition. In seeking a definition of the term ‘resident’ that covers all uses in treaties, the analysis draws on, in addition to the current and earlier iterations of the OECD Model Law itself, such elements as the following: domestic law meaning of residence in the tax law of France, Germany, the Netherlands, the United Kingdom and the United States; Articles 31 and 32 of the Vienna Convention on the Law of Treaties; historical documents that uncover the ordinary meaning of treaty terms; tax treaty case law and court decisions; and fiscal, tax and legal scholarship surrounding the concept of residence for taxation purposes. The analysis includes a comprehensive description of tiebreaker rules, various perspectives on ‘place of effective management’ and policy considerations as to the further development of the treatment of entities under double tax conventions. Given the inordinate importance of the definition of ‘resident’, the differences in interpretation to which the current definition gives rise and the economic developments that call for an evaluation of the provision, this thorough examination of the treaty rules on residence of entities will be welcomed by tax lawyers, corporate counsel and policymakers and academics concerned with tax law. The author’s guidance on the concept of residence for tax purposes and his original proposals for reform will prove of great practical value for tax practitioners.Product details Simultaneous Publisher: Kluwer Law International (September 13, 2019) Publication Date: September 13, 2019