How Long to Read The Missing Keystone of Income Tax Treaties

How Long Does it Take to Read The Missing Keystone of Income Tax Treaties?

It takes the average reader 7 hours and 45 minutes to read The Missing Keystone of Income Tax Treaties by J. Wheeler

Assuming a reading speed of 250 words per minute. Learn more

Description

Le site d'IBFD indique : "This thesis reveals a fundamental flaw in the OECD Model, namely that it pays no attention to the person who is liable to tax in respect of the income for which treaty benefits are claimed. This "missing keystone" causes two major problems of interpretation. One problem arises if the contracting states attribute the income to different persons; the myriad ways in which such a conflict can occur is illustrated by an extensive comparison of the domestic law of the Netherlands and the United Kingdom in this respect. This missing keystone also causes a disconnection between the two principal conditions for treaty entitlement. The treaty residence of the claimant is based on a general liability to tax in a contracting state, whereas the distributive articles focus on the ownership of the income. Interpretation problems arise if domestic law imposes a tax liability on a person who is not the owner of the income, for example under anti-avoidance legislation or a corporate group regime. In order to eliminate this fundamental flaw, the thesis proposes a "new approach" in which the criterion for treaty entitlement is liability to tax on the income, backed up by substantial connections between the income and the treaty claimant and between the treaty claimant and the residence state. The new approach is tested in various situations, many of them decided cases, and proves to give appropriate policy results while respecting the tax sovereignty of states. The thesis includes a proposal for a re-draft of the OECD Model on this basis."

How long is The Missing Keystone of Income Tax Treaties?

The Missing Keystone of Income Tax Treaties by J. Wheeler is 449 pages long, and a total of 116,291 words.

This makes it 152% the length of the average book. It also has 142% more words than the average book.

How Long Does it Take to Read The Missing Keystone of Income Tax Treaties Aloud?

The average oral reading speed is 183 words per minute. This means it takes 10 hours and 35 minutes to read The Missing Keystone of Income Tax Treaties aloud.

What Reading Level is The Missing Keystone of Income Tax Treaties?

The Missing Keystone of Income Tax Treaties is suitable for students ages 12 and up.

Note that there may be other factors that effect this rating besides length that are not factored in on this page. This may include things like complex language or sensitive topics not suitable for students of certain ages.

When deciding what to show young students always use your best judgement and consult a professional.

Where Can I Buy The Missing Keystone of Income Tax Treaties?

The Missing Keystone of Income Tax Treaties by J. Wheeler is sold by several retailers and bookshops. However, Read Time works with Amazon to provide an easier way to purchase books.

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