内容説明
This book provides an excellent, practical resource for international tax practitioners no matter where they are located. Looking at tax treaties from a practical and planning point of view, the book provides an insight into treaty interpretation and application in a number of countries. Other highlights include case studies and OECD model treaties. Written by an expert in the field and taking the practical approach rather than the academic, this truly is an essential global tool for the tax adviser wishing to use tax treaties in tax planning.
目次
Contents: 1. Introduction. 2. Domestic tax law of relevance to the application of tax treaties. 3. The OECD model. 4. Interpretation of tax treaties. 5. Application of selected important treaty provisions. 6. Domestic and treaty-based anti-avoidance measures. 7. Hybrid entities and partnerships. 8. Hybrid financing and financial issues. 9. Special issues. 10. Inheritance tax treaties. 11. Case studies.
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