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"Taxes Covered"
"The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ('Taxes covered') of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpetive issues and uncertainties in practical treaty application. This book not only provides in-depth analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of ...
Tax and Technology
The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, ind...
Access to Treaty Benefits
A rigorous analysis of various aspects related to treaty access Tax treaty access is an ongoing challenge for both taxpayers and tax authorities. This volume provides a rigorous analysis of various aspects related to treaty access. Schematically, the volume is divided into four parts. The first part deals with general interpretative issues and principles; the second and third parts cover a wide range of sub-aspects relating to the subjective and objective scope of tax treaties and the recent challenges posed to tax treaty access, while the fourth part focuses on the knotty issues of treaty shopping and abuse. The structure of the volume reflects the necessity to approach access to treaty ben...
WTO and Direct Taxation
WTO Law and Direct Taxation are linked in numerous ways. The WTO Agreements, thereof especially the GATT and GATS Agreements, contain several explicit provisions on the subject of direct taxes or even on its delimitation from Tax Treaty Law. To some extent, the scope of application of WTO Law has been broadened by case law to comprise also direct taxes. This entails overlappings particularly with regard to the law of subsidies, prohibitions of discrimination, and most-favoured-nation obligations. This book highlights increasingly relevant interdependencies between WTO Law and Direct Taxation from the viewpoint of 21 States. Special emphasis is placed on the conformity of national taxes on pr...
Environmental Border Tax Adjustments and International Trade Law
This timely book brings clarity to the debate on the new legal phenomenon of environmental border tax adjustments. It will help form a better understanding of the role and limits these taxes have on environmental policies in combating global environmental challenges, such as climate change.
City Lives
Devlin, Caroline and Maggie. Women in their prime. They have it all. Careers. Success. Marriage. They are the envy of their peers. But at what price? Just when Devlin has everything she has ever dreamed of, a callous betrayal shows her that there's no room for friendship and loyalty in business. Can she be as tough as she needs to be in a world of deceit and double-dealing, where honesty and integrity are rare commodities? Caroline, fed up being a victim, is no longer shy, unsure and needy. She's about to take a step that will change her life. Then tragedy strikes, and her plans change completely. But when one door closes...another opens. And Maggie, alone, unsupported and unhappy in her marriage, has to make a choice that will put her children's needs before her own. Has she the strength to do what she has to do? City Lives is the story of three women who have one great certainty in their lives. Their friendship. The enduring bonds of loyalty and love will carry them through the worst of times and the best of times.
Patricia Highsmith: Her Diaries and Notebooks
'My secrets - the secrets that everyone has - are here, in black and white.' Before Alfred Hitchcock adapted her debut novel, Strangers on a Train, for the big screen; before Thomas Ripley snaked his way into the canon of psychological suspense; before Carol became a cult classic of romantic obsession, who was Patricia Highsmith? Beginning in 1941 and encompassing Highsmith's adventurous twenties, The New York Years is an intimate self-portrait of a young artist, reading voraciously and honing her craft, intertwined with scenes from her dizzying social life, rife with sleepless nights spent in the queer bars of Greenwich Village. This condensed edition of Highsmith's monumental Diaries and Notebooks offers all the pleasures of her fiction, along with an unparalleled insight into the life, mind and times of this enigmatic, iconic, trailblazing author. 'One of the most observant and ecstatic accounts . . . about being young and alive in New York City' New York Times
