Taxation of cross-border services

Name: Taxation of cross-border services
Author: Rawal Radhakishan

Ingenaaid Engels 2014 1e druk 9789041149473

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Samenvatting

Series on International Taxation Volume 47

Building on a detailed analysis of the OECD and the UN tax treaty models as
regards taxation of cross-border services – their shortcomings as well as
their efficacy – this immensely informative and practical book responds
knowledgeably and precisely to such questions as the following:

What are the provisions for Service PEs in the UN and OECD models and
commentary?

What is the distinction between ‘fees’ and ‘fees for technical services’?

How do the Articles dealing with ‘fees for technical service’, ‘permanent
establishment’, and ‘independent personal services’ interact with each other?

The author spares no pains to convey clearly the implications of such crucial
terms as ‘make available’, ‘effectively connected’, and ‘attributable to’. He
also shows how revisions in service rules from scores of specific bilateral
tax treaties from all over the world presage the emergence of a new global
regime, and how India’s new role as the world’s most significant service
economy has led it to become the major source of guidance in the law of
cross-border taxation. Tax lawyers and consultants and corporate tax advisers
everywhere will benefit hugely from this book as they consult it regularly for
fast and reliable information and guidance. Government officials and academics
in the field will also find here an incomparable resource for understanding
how both authorities and businesses are coping with the intricacies of
taxation of cross-border services.