Taxation of Cross-border Partnerships

Taxation of Cross-border Partnerships

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Aims to identify and analyse problems related to double taxation of income attributable to cross border partnerships in asymmetrical situations de lege lata. This refers to cases where the same partnership, in across border owner/entity situation, is recognized as a taxable person in one country, but as transparent for tax purposes in the other.qPrinciples of double tax relief, the need for rules for foreign entity classification and general principles of business ... Chapter 5 approaches this issue by analysing the applicability of OECD MTC to asymmetrical situations, whereas Chapter 6anbsp;...

Title:Taxation of Cross-border Partnerships
Author: Jesper Barenfeld
Publisher:IBFD - 2005-01-01

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