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Verluste im Recht der Doppelbesteuerungsabkommen

Josef Schuch

出版	Linde, 1998
ISBN	385122812X9783851228120
URL	http://books.google.com.hk/books?id=D6paAAAACAAJ&hl=&source=gbs_api

註釋

Losses in tax treaty law. Carrying on business activities abroad involves special risks which can lead to expenses and losses. Therefore cross-border loss utilization techniques play an important role in tax planning. In addition to domestic law, the provisions of tax treaties have to be taken into account, since they also cover expenses and losses. The impacts of expenses and losses in tax treaty law become apparent especially on the basis of the avoidance method. On the one hand the book describes the allocation of losses in tax treaty law and on the other hand it presents the different legal consequences of losses depending on direction of investment, residency and applicable method (exemption or credit). The book provides the reader with numerous arguments concerning expenses and losses which can be used in daily practice to solve cases of doubt in cross-border situations.