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Article Summary
Ronit Florence, "Draft 2002 Update To The OECD Model Tax Convention - Dudney Revisited", Taxation of Executive Compensation and Retirement, Vol. 13, No. 8, April 2002, p. 115. -- summary under Article 5
Ronit Florence, "Draft 2002 Update To The OECD Model Tax Convention- Dudney Revisited", Taxation of Executive Compensation and Retirement, Vol. 13, No. 8, April 2002, p. 115.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ...
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D. Sandler, J. Li, "The Relationship between Domestic Anti-Avoidance Legislation and Tax Treaties", 1997 Canadian Tax Journal, Vol. 45, No. 5, p. 891. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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Klaus Vogel, "The Influence of the OECD Commentaries on Treaty Interpretation", Bulletin for International Fiscal Documentation, Vol. 54, No. 12, 2000, p.612. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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Jones, David A. Ward, "Agents as Permanent Establishments under the OECD Model Tax Convention", European Taxation, May 1993, p. 154. -- summary under Article 5
Ward, "Agents as Permanent Establishments under the OECD Model Tax Convention", European Taxation, May 1993, p. 154.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 ...
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Paul K. Tanaki, amp; Sarah Davidson Ladly:, "Payments by Hybrid Entities under the Revised Canada-United States Income Tax Convention", Corporate Finance, Vol. XV, No. 4, 2009 p. 1710. -- summary under Article 4
Tanaki, amp; Sarah Davidson Ladly:, "Payments by Hybrid Entities under the Revised Canada-United States Income Tax Convention", Corporate Finance, Vol. XV, No. 4, 2009 p. 1710.-- summary under Article 4 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 4 ...
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Jan de Goed, "Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention: Response from the IBFD Research Staff", Bulletin for International Taxation, Vol 66, No. 6, 2012, p.313 -- summary under Article 5
Jan de Goed, "Interpretation and Application of Article 5 (Permanent Establishment) of the OECD Model Tax Convention: Response from the IBFD Research Staff", Bulletin for International Taxation, Vol 66, No. 6, 2012, p.313-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Commentary on the 2011 OECD discussion draft. ...
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Luc de Broe, "Interpretation of Article 15(2)(b) of the OECD Model Convention: 'Remuneration paid by, or on Behalf of, an employer who is not a resident of the other state'", Bureau of International Fiscal Documentation, Vol. 54, No. 10, October 2000, p. 503. -- summary under Article 15
Luc de Broe, "Interpretation of Article 15(2)(b) of the OECD Model Convention: 'Remuneration paid by, or on Behalf of, an employer who is not a resident of the other state'", Bureau of International Fiscal Documentation, Vol. 54, No. 10, October 2000, p. 503.-- summary under Article 15 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 15 ...
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Richard G. Tremblay, Peter MacDonald, "General-Anti-Avoidance Rule and Treaty Shopping: Why Courts Should Not Be Asked to Do the Job of Legislators", International Tax, Vol. XII, No. 2, 2004, p. 844. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions ...
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Justice Marshall Rothstein, "An Overview of the Supreme Court of Canada", Bulletin for International Taxation (IBFD), January/February 2016, p. 20. -- summary under Income Tax Conventions
.-- summary under Income Tax Conventions Summary Under Tax Topics- Treaties- Income Tax Conventions International rules of interpretation (pp. 24-25) [W]hen interpreting treaties, Canadian courts generally use international rules of interpretation instead of domestic rules. The Supreme Court of Canada has endorsed the principles of treaty interpretation enunciated in sections 31-33 of the Vienna Convention on the Law of Treaties. ...
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Mateusz M. Krauze, "Impact of Cloud Computing on Permanent Establishments Under the OECD Model Tax Convention", Tax Management International Journal, Vol. 44, No. 3, March 13, 2015, p. 131. -- summary under Article 5
Krauze, "Impact of Cloud Computing on Permanent Establishments Under the OECD Model Tax Convention", Tax Management International Journal, Vol. 44, No. 3, March 13, 2015, p. 131.-- summary under Article 5 Summary Under Tax Topics- Treaties- Income Tax Conventions- Article 5 Categories of Cloud-based services (p.132) The models for providing cloud-based services have traditionally been divided into three categories: Software as a Service (SaaS), Platform as a Service (PaaS) and Infrastructure as a Service (laaS). ...