Lexis Nexis The Canada-U.K. Tax Treaty - Text and Commentary
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Détails des produits
The Canada-U.K. Tax Treaty - Text and Commentary is the first comprehensive, up-to-date analysis of this important tax treaty. Next to the United States, the United Kingdom is Canada's most significant trading partner. Commentary includes the fundamentals of international tax treaties.
Features and Benefits
- General tax treaty principles - interpret and apply tax treaties confidently
- Relevant case law - follow examples from the United Kingdom, Australia, New Zealand, India, as well as Europe
- Recent Supreme Court of Canada decisions - discover the impact of Canada Trustco v. Canada 2005 and Mathew v. Canada
- Clause-by-clause comparison of OECD Model and Canada-U.K. Tax Treaty - understand how this tax treaty differs from others
Plus extensive analysis of these key concepts:
- Permanent establishment - determine which country has taxable jurisdiction
- Electronic commerce - determine which country has taxable jurisdiction over revenues
- Investment income - distinguish investment income from business income
- General Anti-Avoidance Rule - eliminate treaty benefits when they don't apply
- Treaty shopping - restrict this abusive practice
Appendices
- Extensive bibliography on tax treaty resources
- OECD Model Tax Convention on Income and on Capital
- Tax Treaty Characterisation Issues Arising from E-commerce
- Income Tax Conventions Interpretation Act
- Convention on Mutual Administrative Assistance on Tax Matters
Table des matières
Chapter 1: Introduction
Chapter 2: Interpretation Of Tax Treaties
Chapter 3: General Principles
Chapter 4: Article 1-Personal Scope
Chapter 5: Article 2-Tax Covered
Chapter 6: Article 3-General Definitions
Chapter 7: Article 4-Domicile
Chapter 8: Article 5-Permanent Establishment
Chapter 9: Article 6-Income From Immovable Property
Chapter 10: Article 7-Business Profits
Chapter 11: Article 8-Shipping, Inland Waterways Transport And Air Transport (OECD)
Chapter 12: Article 9-Associated Enterprises
Chapter 13: Article 10-Dividends
Chapter 14: Article 11-Interest
Chapter 15: Article 12-Royalties
Chapter 16: Article 13-Capital Gains
Chapter 17: Article 14-Professional Services
Chapter 18: Article 15-Dependent Personal Services
Chapter 19: Article 16-Artists And Athletes
Chapter 20: Article 17-Pensions And Annuities
Chapter 21: Article 18-Government Service
Chapter 22: Article 19-Students
Chapter 23: Article 20-Estates And Trusts
Chapter 24: Article 20A-Other Income
Chapter 25: Article 21-Elimination Of Double Taxation
Chapter 26: Article 22-Non-Discrimination
Chapter 27: Article 23-Mutual Agreement Procedure
Chapter 28: Article 24-Exchange Of Information
Chapter 29: Article 25-Diplomatic And Consular Officials
Chapter 30: Article 26-Extension
Chapter 31: Article 27-Miscellaneous Rules
Chapter 32: Article 27A-Miscellaneous Rules Applicable To Certain Offshore Activities
Chapter 33: Article 28-Entry Into Force
Chapter 34: Article 29-Termination
Appendices
