Tax treaty case law around the globe, 2011 / edited by Michael Lang ... [et al.]
Imprint
Alphen aan den Rijn, The Netherlands : Kluwer Law International ; Frederick, MD : Sold and distributed in North, Central and South American by Aspen Publishers, c2012
Descript
514 p. : ill. ; 25 cm
CONTENT
Personal and substantive scope (art 1, 2 and 4 OECD model) -- Canda: tax treaty interpretation and the residence of ahybrid entity -- Romania: form and substance requirements to be met by a tax residence certificate -- Hungary: does the hungarian local trade tax fall within the substantive scope of a DTC? -- Netherlands: how to prove residence of the other contracting state for tax treaty purposes? -- Protugal: deemed residence - the case of households in the light of Article 4(1) OECD MC -- Germany: florida LLC
SUBJECT
International business enterprises -- Taxation -- Law and legislation