Klaus Vogel on Double Taxation Conventions


Book Description

Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs). DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers. Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020. Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom. What’s new in this edition? There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries. You’ll find: Reports about major features in the DTC practice of many leading jurisdictions, such as: the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US Sections on divergent country practice covering their national models and networks of bilateral DTCs Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs. On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences. How this will help you: All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises: Editors: Prof. Dr Ekkehart Reimer, Heidelberg University and Prof. Dr Alexander Rust, WU Vienna. Authors: Johannes Becker, Federal Ministry of Finance, Berlin; Alexander Blank, University of Erlangen-Nuremberg; Katharina Blank, Federal Ministry of Finance, Berlin; Michael Blank, University of Erlangen-Nuremberg, Prof. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula Dourado, University of Lisbon; Daniela Endres-Reich, University of Erlangen-Nuremberg; Prof. Dr Werner Haslehner, University of Luxembourg; Prof. Dr Roland Ismer, University of Erlangen-Nuremberg; Prof. Dr Eric C. C. M. Kemmeren , Tilburg University; Prof. Dr Georg Kofler, WU Vienna; Sophia Piotrowski, University of Erlangen-Nuremberg; Prof. Dr Ekkehart Reimer, Heidelberg University; Prof. Dr Alexander Rust, WU Vienna; Annika Streicher, WU Vienna; Prof. Dr. Matthias Valta, Duesseldorf University; Jens Wittendorff, Ernst & Young, Copenhagen and University of Aarhus; Kamilla Zembala, Heidelberg University




NISTIR.


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West German Industry and the Challenge of the Nazi Past


Book Description

In this groundbreaking study, S. Jonathan Wiesen explores how West German business leaders remade and marketed their public image in the aftermath of World War II and the Holocaust. He challenges assumptions that West Germans - and industrialists in particular - were silent about the recent past during the years of denazification and reconstruction, revealing how German business leaders attempted to absolve themselves of responsibility for Nazi crimes while recasting themselves as socially and culturally engaged public figures. Through case studies of individual firms such as Siemens and Krupp, Wiesen depicts corporate publicity as a telling example of postwar selective memory.




Weimar Germany


Book Description

The Weimar Republic was born out of Germany's defeat in the First World War and ended with the coming to power of Hitler and his Nazi Party in 1933. In many ways, it is a wonder that Weimar lasted as long as it did. Besieged from the outset by hostile forces, the young republic was threatened by revolution from the left and coups d'états from the right. Plagued early on by a wave of high-profile political assassinations and a period of devastating hyper-inflation, its later years were dominated by the onset of the Great Depression. And yet, for a period from the mid-1920s it looked as if the Weimar system would not only survive but even flourish, with the return of economic stability and the gradual reintegration of the country into the international community. With contributions from an international team of ten experts, this volume in the Short Oxford History of Germany series offers an ideal introduction to Weimar Germany, challenging the reader to rethink preconceived ideas of the republic and throwing new light on important areas, such as military ideas for reshaping society after the First World War, constitutional and social reform, Jewish life, gender, and culture.




Publication


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Understanding and Applying Advanced On-board Bus Electronics


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The report provides an overview of electronics and its application to buses and other transportation sectors. The report then addresses electronic integration, potential benefits offered by integration, and transit agency experiences with the technology. The report concludes with guidelines for implementing transit bus electronics. It is intended to be a primer on the subject, providing essential background information to serve as a starting point for acquiring additional knowledge.




Theory and Application of Graph Transformations


Book Description

Theareaofgraphtransformationoriginatedinthelate1960sunderthename “graph grammars” – the main motivation came from practical considerations concerning pattern recognition and compiler construction. Since then, the list of areas which have interacted with the development of graph transformation has grown impressively. The areas include: software speci?cation and development, VLSI layout schemes, database design, modeling of concurrent systems, m- sively parallel computer architectures, logic programming, computer animation, developmentalbiology,musiccomposition,distributedsystems,speci?cationl- guages, software and web engineering, and visual languages. As a matter of fact, graph transformation is now accepted as a fundamental computation paradigm where computation includes speci?cation, programming, and implementation. Over the last three decades the area of graph transfor- tion has developed at a steady pace into a theoretically attractive research ?eld, important for applications. Thisvolume consistsofpapersselectedfromcontributionsto the Sixth Int- national Workshop on Theory and Applications of Graph Transformation that took place in Paderborn, Germany, November 16-20, 1998. The papers und- went an additional refereeing process which yielded 33 papers presented here (out of 55 papers presented at the workshop). This collection of papers provides a very broad snapshot of the state of the art of the whole ?eld today. They are grouped into nine sections representing most active research areas. Theworkshopwasthe sixth in a seriesof internationalworkshopswhich take place every four years. Previous workshops were called “Graph Grammars and Their Application to Computer Science”. The new name of the Sixth Workshop re?ectsmoreaccuratelythecurrentsituation,whereboththeoryandapplication play an equally central role.




The New Security Concept and German-French Approaches to the European "Pillar of Defence," 1990-2000


Book Description

A historic opportunity without precedent is gradually becoming reality in the 21st Century with the chance taken to pave the way in the period 1990-2000 towards the organisation of defence in Europe. The corresponding conditions have been brought about by concrete steps taken at the Masstricht, Amsterdam, Cologne, Helsinki, and Nice European Council meetings. In the end, the EU/WEU is developing into an 'equal' partner to the US by assuming greater responsibility in the security and defence sphere. The French and German bilateral relationship - which is the driving force behind every European integration process - is the historical force behind this development of the ultimate desire to reach a robust European 'Pillar of Defence' through reconfiguration of the transatlantic relationship. This book provides the first comprehensive and up-to-date analysis of German and French approaches to the European 'Pillar of Defence' from the view of 'Europeanisation' emanating from the process of integration.




Europe's Angry Muslims


Book Description

Europe's Angry Muslims traces the routes, expectations and destinies of immigrant parents and the plight of their children, transporting both the general reader and specialist from immigrants' ancestral villages to their new enclaves in Europe. It guides readers through Islamic nomenclature, chronicles the motive force of the Islamist narrative, offers them lively portraits of jihadists, and takes them inside radical mosques and into the minds of suicide bombers. Through interviews of former radicals and security agents and examination of the sermons of radical imams, Robert Leiken presents an unsentimental yet compassionate account of Islam's growing presence in the West. His nuanced and authoritative analysis-historical, sociological, theological and anthropological-warns that conflating rioters and Islamists, folk and fundamentalist Muslims, pietists and jihadis, and immigrants and their children is the method of strategic incoherence. Now with a new preface analyzing the rise of ISIL, this book offers a cogent overview of how global terror and its responding foreign policy interacts with the lives of Muslim, first-and second generation immigrants in Europe.




Machine Learning and Data Mining in Pattern Recognition


Book Description

We met again in front of the statue of Gottfried Wilhelm von Leibniz in the city of Leipzig. Leibniz, a famous son of Leipzig, planned automatic logical inference using symbolic computation, aimed to collate all human knowledge. Today, artificial intelligence deals with large amounts of data and knowledge and finds new information using machine learning and data mining. Machine learning and data mining are irreplaceable subjects and tools for the theory of pattern recognition and in applications of pattern recognition such as bioinformatics and data retrieval. This was the fourth edition of MLDM in Pattern Recognition which is the main event of Technical Committee 17 of the International Association for Pattern Recognition; it started out as a workshop and continued as a conference in 2003. Today, there are many international meetings which are titled “machine learning” and “data mining”, whose topics are text mining, knowledge discovery, and applications. This meeting from the first focused on aspects of machine learning and data mining in pattern recognition problems. We planned to reorganize classical and well-established pattern recognition paradigms from the viewpoints of machine learning and data mining. Though it was a challenging program in the late 1990s, the idea has inspired new starting points in pattern recognition and effects in other areas such as cognitive computer vision.