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Taxation of Intercompany Dividends Under Tax Treaties and EU Law
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
E-business and Telecommunications
This book contains the best papers of the 4th International Conference on E-business and Telecommunications (ICETE), which was held during July 28–31, 2007 in Barcelona, Spain. The conference reflects a continuing effort to increase the dissemination of recent research results among professionals who work in the areas of e-business and telecommunications. ICETE is a joint international conf- ence integrating four major areas of knowledge that are divided into four cor- sponding conferences: ICE-B (International Conference on e-Business), SECRYPT (International Conference on Security and Cryptography), WINSYS (International Conference on Wireless Information Systems) and SIGMAP (Internation...
The Provisional Austrian Regime in Lombardy–Venetia, 1814–1815
When Austrian soldiers first set foot in Lombardy-Venetia in October, 1813, they were greeted everywhere as liberators and friends. In the spring of 1815, when Joachim Murat's efforts to establish a united Italy ended in miserable failure and when the Habsburgs announced the main features of the regime they intended to establish in their Italian provinces, the Venetians were still strongly pro-Austrian, but considerable anti-Habsburg feeling had developed among the Lombards. This carefully documented study of the first two years of Austrian reoccupation of Lombardy-Venetia examines all aspects of the Habsburg provisional regimes and draws some conclusions about the reasons for the different ...
E-Business and Telecommunication Networks
This book contains the best papers of the Third International Conference on E-business and Telecommunications (ICETE), which was held in 2006 in Portugal. This conference reflects a continuing effort to increase the dissemination of recent research results among professionals who work in the e-business field. ICETE is a joint international conference integrating four major areas of knowledge that are divided into four cor- sponding conferences: ICE-B (Int’l Conf. on e-Business), SECRYPT (Int’l Conf. on Security and Cryptography), WINSYS (Int’l Conf. on Wireless Information Systems) and SIGMAP (Int’l Conf. on Signal Processing and Multimedia). The program of this joint conference incl...
