Law Commons^™

Panelist, A Policy Framework For Knowledge-Based Capital, Hugh Ault

Hugh J. Ault

No abstract provided.

Är Det Möjligt Att Utforma Eu-Förenliga Skatteflyktsregler? En Analys Med Särskilt Fokus På Eu-Domstolens Proportionalitetsbedömning, Maria Hilling

Maria Hilling

No abstract provided.

Akteure Des Internationalen Steuerrechts Und Ihre Handlungsformen, Hugh Ault

Hugh J. Ault

No abstract provided.

The International Tax Bible - Management (Intra-Group) Service Fee Case, Sung-Soo Han

Sung-Soo Han

The International Tax Bible - Treaty Shopping Case, Sung-Soo Han

Sung-Soo Han

This position paper was made for the purpose of discussion with the Korean tax authority during the tax audit period against a foreign subsidiary company doing business in Korea. This kind of tax audit defense approach was a new one at that time. This position paper was inserted in the book "the International Tax Bible(국제조세바이블)" which was published in January 2012. When this report was made, there was no specific rules concerning the "treaty shopping" in the Korean tax law and thus there often took place conflicts between taxpayers and tax authorities with regard to the appropriateness of treaty shopping. …

The International Tax Bible - Transfer Pricing Case, Sung-Soo Han

Sung-Soo Han

China, Wei Cui

Wei Cui

This overview of the current state of China’s income tax treaties highlights three themes. First, the OECD and UN Model Conventions have shaped not only the treaties that China has negotiated but also the country’s domestic tax law itself. A significant number of concepts were introduced into domestic law primarily by borrowing from the treaty framework: these transplants have sometimes enriched affiliated concepts in domestic law, but in other cases, due to the limitations in the treaty framework itself, have held back the development of domestic law. Second, there are important examples where conflicts between China’s treaty obligations and its …