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Taxation of Cross-Border Services by Rawal Radhakishan

Taxation of Cross-Border Services

By Rawal Radhakishan


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Series on International Taxation Volume 47

Building on a detailed analysis of the OECD and the UN tax treaty models as regards taxation of cross-border services – their shortcomings as well as their efficacy – this immensely informative and practical book responds knowledgeably and precisely to such questions as the following:

  • What are the provisions for Service PEs in the UN and OECD models and commentary?
  • What is the distinction between ‘fees’ and ‘fees for technical services’?
  • How do the Articles dealing with ‘fees for technical service’, ‘permanent establishment’, and ‘independent personal services’ interact with each other?
The author spares no pains to convey clearly the implications of such crucial terms as ‘make available’, ‘effectively connected’, and ‘attributable to’. He also shows how revisions in service rules from scores of specific bilateral tax treaties from all over the world presage the emergence of a new global regime, and how India’s new role as the world’s most significant service economy has led it to become the major source of guidance in the law of cross-border taxation. Tax lawyers and consultants and corporate tax advisers everywhere will benefit hugely from this book as they consult it regularly for fast and reliable information and guidance. Government officials and academics in the field will also find here an incomparable resource for understanding how both authorities and businesses are coping with the intricacies of taxation of cross-border services.

Resources Table of Contents
Pages 480
Last Updated 10/02/2014
Update Frequency As Needed
Product Line Kluwer Law International
ISBN 9789041149473
SKU 10059529-0001
Table of Contents

About the Author.



Chapter 1 General Overview of Taxation of Cross-Border Services.

Chapter 2 FTS Article – Part I.

Chapter 3 FTS Article – Part II.

Chapter 4 Make Available.

Chapter 5 Effectively Connected Fees for Technical Services.

Chapter 6 Article 12 versus Article 14.

Chapter 7 Applicability of Other Source Article to the Fees for Technical Services.

Chapter 8 Service PE – Part I.

Chapter 9 Service PE – Part II.

Chapter 10 OECD Service PE Provision.

Chapter 11 Paragraph 2 of Article 3.

Chapter 12 United Nation’s Work on Taxation Services.

Chapter 13 Taxation under the Indian Domestic Law.