Conflicts of qualification in tax treaty law
By: edited by Eva Burgstaller, Katharina Haslinger
Series: Schriftenreihe zum internationalen Steuerrecht -- Bd. 52
Publisher: Linde
Published: 2007
Place of publication: Wien
Language: eng
Number of pages: 406
ISBN-13: 9783707312041
Subjects: Double taxation; Treaties; Taxation; Law and legislation
Description: Conflicts of qualification arise because of diverging tax treaty application by the contracting states. The different allocation of taxing rights may lead to double taxation or double non-taxation which can be (un-)favourable for the taxpayers and tax administrations involved. The practical experience shows that there is a wide variety of possible conflicts of qualification. The master theses contained in this volume are dedicated to identifying conflicts of qualification and to develop solutions to the respective situations. Thereby, methodical issues are equally covered as the application of the distributive rules and the articles to avoid double taxation. The theses consider general aspects of conflicts of qualification, tax treaty provisions, special cross-border situations, and possible solutions for resolving conflicts of qualification.
Notes: Collection of master's theses of the 2006/2007 postgraduate LLM program "International Tax Law" at the Vienna University of Economics and Business Administration.

"Postgraduate International Tax Law."

Includes bibliographical references and index.