The Resource The Application of the OECD Model Tax Convention to Partnerships, Organisation for Economic Co-operation and Development, (electronic resource)

The Application of the OECD Model Tax Convention to Partnerships, Organisation for Economic Co-operation and Development, (electronic resource)

Label
The Application of the OECD Model Tax Convention to Partnerships
Title
The Application of the OECD Model Tax Convention to Partnerships
Statement of responsibility
Organisation for Economic Co-operation and Development
Title variation
Issues in International Taxation, no.6
Creator
Contributor
Contributor
Subject
Language
  • eng
  • eng
Summary
The application of tax treaties to cases involving partnerships raises a number of complex issues. When is a partnership entitled to the benefits of a tax convention? What happens when the residence and source States apply different articles of the Convention on the basis of differences in their domestic law? How can the problems arising from conflicts of income allocation be solved? This report addresses these issues in detail and focuses on specific factual examples. For each example, the facts and, where applicable, relevant aspects of domestic tax laws are described. Comprehensive recommendations for dealing with the international taxation of partnerships in practice are also presented
Member of
Is Subseries of
Cataloging source
FR-PaOEC
http://bibfra.me/vocab/relation/contentprovider
  • GkpX9c6P1gc
  • O72GiO16UoE
Government publication
international or intergovernmental publication
Illustrations
illustrations
Language note
English
LC call number
K4543.5.A97 1999
Literary form
non fiction
Nature of contents
dictionaries
http://bibfra.me/vocab/lite/organizationName
Organisation for Economic Co-operation and Development.
http://library.link/vocab/relatedWorkOrContributorName
  • Organisation for Economic Co-operation and Development
  • Organisation for Economic Co operation and Development
  • Organisation for Economic Co-operation and Development
Series statement
Issues in International Taxation,
Series volume
no.6
http://library.link/vocab/subjectName
  • Taxation
  • Industry and Services
  • Partnership
  • Double taxation
  • Law, Politics & Government
  • Law, General & Comparative
Label
The Application of the OECD Model Tax Convention to Partnerships, Organisation for Economic Co-operation and Development, (electronic resource)
Instantiates
Publication
Note
Bibliographic Level Mode of Issuance: Monograph
Abbreviated title
  • APPLICATION OF THE OECD MODEL TAX CONVENTION TO PARTNERSHIPS ISSUES IN INTERNATIONAL TAXATION NO. 6
  • APPLICATION OF THE OECD MODEL TAX CONVENTION TO PARTNERSHIPS
  • ISSUES IN INTERNATIONAL TAXATION
Antecedent source
not applicable
Carrier category
online resource
Carrier category code
cr
Content category
text
Content type code
txt
Contents
I. Introduction -- I.1 Background -- I.2 Organization of the Report -- II. Application of Tax Conventions by the State of Source -- -II.1 Preliminary Remarks on the Tax Treatment of Foreign Entities -- II.2 Differences that Affect the Tax Treatment of Partnerships -- II.3 When is a Partnership Entitled to the Benefits of a Tax Convention? -- II.4 The Partners' Entitlement to Treaty Benefits when the Partnership is Not a Resident -- II.5 Entitlement to Treaty Benefits when one State Treats the Partnership as a Taxable Entity -- II.6 Application of the Convention where the Benefits are Dependent upon Certain Characteristics or Attributes of the Taxpayer -- III. Applicaton of Tax Conventions by the State of Residence -- -III.1 Conflicts of Qualification -- III.2 Problems Arising form Conflicts of Income Affiliation -- Annex I. Proposed Changes to the OECD Model Tax Convention -- Articles of the Model -- Commentary -- Annex II: Reservations -- France -- Germany -- The Netherlands -- Portugal -- Switzerland -- Appendix III: List of Entities in Selected Countries
Extent
1 online resource (132 p. )
File format
multiple file formats
Form of item
online
Isbn
9789264173316
Media category
computer
Media type code
c
Other control number
10.1787/9789264173316-en
Other physical details
ill..
Specific material designation
remote
System control number
  • (FR-PaOEC)9789264173316-en
  • (SSID)ssj0000090492
  • (PQKBManifestationID)11130540
  • (PQKBTitleCode)TC0000090492
  • (PQKBWorkID)10099523
  • (PQKB)11538066
  • (EXLCZ)99111093034089120
Label
The Application of the OECD Model Tax Convention to Partnerships, Organisation for Economic Co-operation and Development, (electronic resource)
Publication
Note
Bibliographic Level Mode of Issuance: Monograph
Abbreviated title
  • APPLICATION OF THE OECD MODEL TAX CONVENTION TO PARTNERSHIPS ISSUES IN INTERNATIONAL TAXATION NO. 6
  • APPLICATION OF THE OECD MODEL TAX CONVENTION TO PARTNERSHIPS
  • ISSUES IN INTERNATIONAL TAXATION
Antecedent source
not applicable
Carrier category
online resource
Carrier category code
cr
Content category
text
Content type code
txt
Contents
I. Introduction -- I.1 Background -- I.2 Organization of the Report -- II. Application of Tax Conventions by the State of Source -- -II.1 Preliminary Remarks on the Tax Treatment of Foreign Entities -- II.2 Differences that Affect the Tax Treatment of Partnerships -- II.3 When is a Partnership Entitled to the Benefits of a Tax Convention? -- II.4 The Partners' Entitlement to Treaty Benefits when the Partnership is Not a Resident -- II.5 Entitlement to Treaty Benefits when one State Treats the Partnership as a Taxable Entity -- II.6 Application of the Convention where the Benefits are Dependent upon Certain Characteristics or Attributes of the Taxpayer -- III. Applicaton of Tax Conventions by the State of Residence -- -III.1 Conflicts of Qualification -- III.2 Problems Arising form Conflicts of Income Affiliation -- Annex I. Proposed Changes to the OECD Model Tax Convention -- Articles of the Model -- Commentary -- Annex II: Reservations -- France -- Germany -- The Netherlands -- Portugal -- Switzerland -- Appendix III: List of Entities in Selected Countries
Extent
1 online resource (132 p. )
File format
multiple file formats
Form of item
online
Isbn
9789264173316
Media category
computer
Media type code
c
Other control number
10.1787/9789264173316-en
Other physical details
ill..
Specific material designation
remote
System control number
  • (FR-PaOEC)9789264173316-en
  • (SSID)ssj0000090492
  • (PQKBManifestationID)11130540
  • (PQKBTitleCode)TC0000090492
  • (PQKBWorkID)10099523
  • (PQKB)11538066
  • (EXLCZ)99111093034089120

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