Get Fifth International Conference of the Legal Profession Monte PDF

By Franz Martin Joseph

ISBN-10: 9401524238

ISBN-13: 9789401524230

ISBN-10: 9401536759

ISBN-13: 9789401536752

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Extra info for Fifth International Conference of the Legal Profession Monte Carlo (Monaco) July 19–24, 1954: Income Tax Treaties — A Comparison of Basic Provisions

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XX; France, Title II, Art. 14; Greece, Art. XVII; Netherlands, Art. XXIV; New Zealand, Art. XVIII(I); Norway, Art. XIX; Sweden, Art. XX; Switzerland, Art. XVII(I); Union of South Africa, Art. XIII. The treaties with Ireland and the United Kingdom, while reciting the general prohibitions against imposition of more burdensome taxes, contain no provision specifying the method for claiming relief from double taxation.

S. tax on such British or Irish royalties, are under the treaties exempt from British or Irish taxes thereon. If a permanent establishment exists, the appropriate foreign taxes still cannot be credited since the treaty credit sections refer only to taxes appropriate to dividends. 17. Biddle v. Conlln'r, 302 l'S 573 (1938). IS" Art. XIII(I). ,>1 Art. 528. 18. See prior discussion of concept of corporate residence under British and Irish income tax laws. 528. The Irish convention enlarges the proportion of the credit for Irish taxes allowable under IRC § 131, in certain cases, by providing that income derived from United Kingdom sources hy un individual resident of Ireland shall be deemed to be income from Irish sources provided it is not subject to United Kingdom income tax.

XVIII(I); Norway, Art. XIX; Sweden, Art. XX; Switzerland, Art. XVII(I); Union of South Africa, Art. XIII. The treaties with Ireland and the United Kingdom, while reciting the general prohibitions against imposition of more burdensome taxes, contain no provision specifying the method for claiming relief from double taxation.

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Fifth International Conference of the Legal Profession Monte Carlo (Monaco) July 19–24, 1954: Income Tax Treaties — A Comparison of Basic Provisions by Franz Martin Joseph


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