(159) As a result, matters regarding social security taxation would be subject to information exchange under tax treaties
even if otherwise excluded under the general scope of these treaties.
When it comes to the application of such general provision of domestic tax laws to bilateral tax treaties
, however, there are two conflicting views in the academic circle.
See Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, with Exchange of Letters [Signed at Stockholm September 1, 1994; entered into force October 26, 1995; Tax Treaties
(CCH) 8801, Tax Treaties
Because a favorable income tax treaty will often eliminate or minimize such taxes, it is often necessary to organize the IPCo in a jurisdiction with favorable tax treaties
income tax treaties
with other countries may override provisions of the IRC, treating individuals that otherwise would be considered resident aliens as nonresident aliens.
As a signatory, the Philippines will have an "efficient and expeditious way of increasing our tax treaty network from 28 to 59 treaty partners, saving time, financial, and human resources spent on negotiating and updating bilateral tax treaties
, which usually take five to 10 years to complete," the DOF said.
income tax treaties
currently in effect contain a derivative benefits provision within the LOB article:
Deloitte's seminars in the Kingdom focussed on Zakat, double tax treaties
with the EU, and capital gains taxes
In a recently published draft interpretation note ("Application of Double Tax Treaties
to Partnerships" Section 5 (May 10, 2007)), Germany's federal financial oversight body (Bundesfinanzministerium) took the position that only the German approach needs to be applied in (international) partnership cases and that interest payments are therefore to be classified as part of the business profits in cross-border situations.
The organization focuses on performing research, offering continuing education, and publishing books, journals, and newsletters on international tax, tax treaties
, and transfer pricing.
His master thesis on "Subject-to-Tax Clauses in Austrian Tax Treaties
," which was published in Michael Lang's Series on International Tax Law in 2004, was awarded both the "Wolfgang Gassner Science Prize 2005" and the "Talenta 2005 Prize" for having one of the five best master theses at the Vienna University of Economics and Business Administration.