Search results with tag "Tax convention"
UNITED STATES - BELGIUM INCOME TAX CONVENTION
www.irs.govthe convention. The existing income-tax convention of October 28, 1948 with Belgium. as modified by supplementary conventions of September 9, 1952, and August 22, 1957, and by the protocol of May 21, 1965, would be terminated and replaced by the new convention upon the coming into force of the latter.
UK/INDIA DOUBLE TAXATION CONVENTION tax, from 1 …
assets.publishing.service.gov.uk(1) In this Convention, unless the context otherwise requires: (a) the term "United Kingdom" means Great Britain and Northern Ireland; (b) the term "India" means the Republic of India; (c) the term "tax" means United Kingdom tax or Indian tax, as the context requires but
UNITED STATES - MEXICO INCOME TAX CONVENTION
www.irs.govThe income tax Convention, the first between the two countries, is intended to reduce the distortions (double taxation or excessive taxation) that can arise when two countries tax the same income, thereby enabling United States firms to compete on a more equitable basis in Mexico and enhancing the
Double Taxation Avoidance Agreements - Deloitte
www2.deloitte.comItems of income of a resident of a Contracting State, wherever arising, not dealt with in the DTAA • Article 21 (3) of the UN Model Tax Convention provides for source based taxation of other income. It gives States the right to tax other income where their domestic legislation provides for the taxation of that income.
GENERAL EFFECTIVE DATE UNDER ARTICLE 28: 1 ... - IRS tax …
www.irs.govThe Convention is based to a large extent on the United States draft model income tax convention published by the Department of the Treasury in June 1981 and the OECD model published in January 1977. It takes into account changes in the income tax laws and tax treaty policies of the two countries.
ARTICLES OF THE MODEL CONVENTION WITH RESPECT TO …
www.oecd.orgOECD MODEL TAX CONVENTION 8 OECD Article 4 RESIDENT 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of his domicile, residence, place of management or any other criterion of a similar nature, and
COMMENTARIES ON THE ARTICLES OF THE MODEL TAX …
www.oecd.orgApplication of the OECD Model Tax Convention to Partnerships”, 1 the conclusions of which have been incorporated below and in the Commentary on various other provisions of the Model Tax Convention. 3. As discussed in that report, a main source of difficulties is the fact that some
COMMENTARIES ON THE ARTICLES OF THE MODEL TAX …
www.oecd.orgmodel tax convention (condensed version) – isbn 978-92-64-08948-8 – © oecd 2010 45 commentary on article 1 concerning the persons covered by the convention
2017 UPDATE TO THE MODEL TAX CONVENTION - OECD
www.oecd.orgTax Convention, which had not been finalised at the time the Report on Action 6 was approved. ... BEPS Action 7 with previous work on the interpretation and application of Article 5. The ... discussed at a7 September 2012 public consultation and subsequently released in a revised …
OECD MODEL TAX CONVENTION: REVISED PROPOSALS CONCERNING ...
www.oecd.orgoecd model tax convention: revised proposals concerning the interpretation and application of article 5 (permanent establishment) 19 october 2012 to 31 january 2013
Canadian withholding tax guide - apps.rbcits.com
apps.rbcits.com3.4. Exemption under article XXI of Canada/US tax convention 10 3.5. Exemption under certain other treaties for pension or retirement plans 10 4. Refund of excess non-resident tax withheld at source 12 4.1. Introduction 12 4.2. Refund process for claims during the same calendar year 12 4.3. NR7-R process for refund claims to the CRA 12 4.3.1.
OECD MODEL TAX CONVENTION: REVISED …
www.oecd.orgoecd model tax convention: revised proposals concerning the meaning of “beneficial owner” in articles 10, 11 and 12 19 october 2012 to 15 december 2012
OECD MODEL TAX CONVENTION: Tax Treaty Treatment of ...
www.oecd.org2.5 A payment made with respect to unused holidays / sick days that accrued during the last year of employment is part of the remuneration for the period of work that generated the holiday
Clarification of the Meaning of “Beneficial Owner” …
www.oecd.org© IBFD 2011 Page 1 of 6 Clarification of the Meaning of “Beneficial Owner” in the OECD Model Tax Convention Response from IBFD Research Staff1 I Introduction
ISSUES RELATED TO ARTICLE 17 OF THE MODEL …
www.oecd.orgISSUES RELATED TO ARTICLE 17 OF THE MODEL TAX CONVENTION. Adopted by the OECD Committee on Fiscal Affairs on 26 June 2014
TAX CONVENTION WITH THE NETHERLANDS GENERAL …
www.irs.govJan 01, 1994 · follows the pattern of other recent U.S. income tax treaties and is based on the U.S. and OECD Model treaties and recent income tax conventions of both parties. It will serve to modernize tax relations between the two countries. I recommend that the Senate give early and favorable consideration to the Convention and give its
Convention Signed at London December 31 ... - IRS tax forms
www.irs.govUnited States income tax treaties, and to the model income tax convention of the Organization for Economic Cooperation and Development. There are, however, several provisions in the Convention with the United Kingdom which require special comment. Article 10 (Dividends) represents a new approach to meshing, by treaty, two tax systems which
TAX CONVENTION WITH THE CZECH REPUBLIC
www.irs.govJan 01, 1993 · America and the Czech Republic for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed in Prague on September 16, 1993. The new Convention will be the first income tax convention between the two countries, and is part of
TAX CONVENTION WITH SWISS CONFEDERATION
www.irs.govJan 01, 1998 · This Convention is similar to the tax treaties between the United States and other OECD nations. It provides for maximum rates of tax to be applied to various types of income, protection from double taxation of income, exchange of information, and rules to limit the benefits of the Convention to persons that are not engaged in treaty shopping.
TAX CONVENTION WITH SOUTH AFRICA - IRS tax forms
www.irs.govJan 01, 1998 · establishment located in that country. The proposed Convention, however, grants rights to tax business profits that generally are somewhat broader than those found in the U.S. and OECD model treaties. Under the proposed Convention, pursuant to the …
TAX CONVENTION WITH THE STATE OF ISRAEL
www.irs.govThe remaining provisions of the draft treaty dealing with the taxation of business profits, personal service income and administrative matters are patterned largely after other recent United States income tax treaties. Attached to the treaty is a note of transmittal similar to the note presented at the signing of our treaty
TAX CONVENTION WITH THE REPUBLIC OF INDONESIA …
www.irs.govJan 01, 1990 · July 11, 1988. I also transmit for the information of the Senate the report of the Department of State with respect thereto. The Convention is the first tax treaty to be negotiated between the United States and
Convention Signed at Washington July 1, 1957; …
www.irs.govJOHN FOSTER DULLES. (Enclosure: Income-tax convention with Pakistan.) LETTER OF TRANSMITTAL THE WHITE HOUSE, July …
Tax and Duty Manual Part 35A-01-01 Transfer Pricing
www.revenue.iethe substitution of a revised section 835E. Of note, section 15 of Finance Act 2020 is the subject of a Ministerial commencement order and has not yet come into effect. On this basis, while the amendments provided for in section 15 of Finance Act 2020 ... 1 Model Tax Convention on Income and on Capital (November 2017)
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