LEADER 03109nam 2200505 450 001 9910823208803321 005 20230809230247.0 010 $a90-8722-424-9 035 $a(CKB)3840000000350092 035 $a(MiAaPQ)EBC6176455 035 $a(EXLCZ)993840000000350092 100 $a20200731d2017 uy 0 101 0 $aeng 135 $aurcnu|||||||| 181 $ctxt$2rdacontent 182 $cc$2rdamedia 183 $acr$2rdacarrier 200 10$aTaxation of services in treaties between developed and developing countries $ea proposal for new guidelines /$fFernando Souza de Man 210 1$aAmsterdam, The Netherlands :$cIBFD,$d[2017] 210 4$dİ2017 215 $a1 online resource (xxviii, 370 pages) 225 1 $aIBFD Doctoral series ;$vVolume 39 311 $a90-8722-421-4 320 $aIncludes bibliographical references (page 327-370). 330 8 $aThe ease with which services are provided cross-border has increased considerably through the years, but this has not been reflected in the model conventions. Although this may not be an important issue when the flow of services between states is similar, it can have a huge impact on the collecting rights of states into which these services are mainly imported, such as developing countries. Nonetheless, developing countries? claims for more source taxation of services have been consistently neglected in model conventions. With the intent of analysing whether the claims of developing countries are valid, as well as examining how the current system was structured, the author studies the legal and economic theories that support source and residence taxation and the historical documents concerning model conventions drafted by the League of Nations, the OECD and the United Nations. Furthermore, to better grasp the perspective of developing countries, the author analyses the situations of Brazil and India regarding the taxation of services in their domestic legislation and in their tax treaties, comparing the provisions of the latter with the current provisions in model tax conventions. 410 0$aDoctoral series ;$vVolume 39. 606 $aDouble taxation$zDeveloping countries$vTreaties 606 $aDouble taxation$zDeveloped countries$vTreaties 606 $aService industries$xTaxation$xLaw and legislation$zDeveloping countries 606 $aService industries$xTaxation$xLaw and legislation$zDeveloped countries 607 $aDeveloping countries$xForeign economic relations$zDeveloped countries 607 $aDeveloped countries$xForeign economic relations$zDeveloping countries 615 0$aDouble taxation 615 0$aDouble taxation 615 0$aService industries$xTaxation$xLaw and legislation 615 0$aService industries$xTaxation$xLaw and legislation 676 $a343.0526 700 $aSouza de Man$b Fernando$01658340 801 0$bMiAaPQ 801 1$bMiAaPQ 801 2$bMiAaPQ 906 $aBOOK 912 $a9910823208803321 996 $aTaxation of services in treaties between developed and developing countries$94012291 997 $aUNINA