Income from international private employment : an analysis of article 15 of the OECD model / Frank Pötgens.

Format:

Book

Thesis/Dissertation

Contributor:

Pötgens, F. P. G.

Series:

Doctoral series, 1570-7164 ; v. 12.

Language:

English

Subjects (All):

Taxation--Law and legislation.

International law--Interpretation and construction.

Local Subjects:

Taxation--Law and legislation.

International law--Interpretation and construction.

Physical Description:

xxxvi, 1020 s. ; 24 cm.

Place of Publication:

Amsterdam : IBFD, 2006.

Summary:

This study considers the treatment of income from private employment under tax treaties containing provisions analogous or similar to Article 15 of the OECD Model.Why this book? This study considers the treatment of income from private employment under tax treaties containing provisions analogous or similar to Article 15 of the OECD Model. It offers an in-depth analysis of these provisions as well as suggestions for improvements in the application and interpretation.It approaches the analysis of Article 15 of the OECD Model from the perspective of five key countries: Belgium, Germany, the Netherlands, the United Kingdom and the United States. By analysing case law, legal literature and official policy statements of these countries' respective tax authorities, the study also describes potential difficulties.An overview is provided of the various interpretations and explanations employed in these countries, which is also used by the author in developing a preferred interpretation of a term at issue.

Notes:

Thesis (doctoral) - Erasmus University, Rotterdam, 2007.

Includes bibliographical references (p. 901-997).

ISBN:

9789087220013

9087220014