Essays on the International Legal and Institutional Structures of Double Taxation Agreements
By Edwin Vanderbruggen
Double taxation agreements are the cornerstone of international income tax regulation. They address double taxation, transfer pricing, dual residence and other international income tax issues. But a DTA is not only operative between taxpayer and tax administration. Treaties create relationships between states, and between states and international third parties. On a multilateral level, the way a treaty is concluded, applied or interpreted may have legal consequences as well, especially involving international organizations. The essays in this book highlight special problems and issues related to the international legal and institutional structure of tax treaties.
Source Taxation of Business, Construction and Services under Double Taxation Agreements
By Edwin Vanderbruggen
A highly practical and in-depth analysis, “Vietnam Taxation of Permanent Establishments and the Foreign Contractor Tax” is the indispensable guide to Vietnam’s taxation at source of cross-border income. The author explains how Vietnam’s withholding tax regime, the Foreign Contractor Tax, operates in conjunction with double taxation agreements, particularly with respect to the concept of permanent establishment and the rules on the international attribution of income.The author combines his knowledge of Vietnamese tax regulations, rulings and practices, with treaty rules, case law and international commentaries.
Edwin Vanderbruggen has 20 years of experience as a tax lawyer, academic, author and government adviser. He has taught international tax law at six universities in Europe and Asia, and has given a number of lectures at the prestigious International Tax Center in Leyden. An award-winning author, he has published seven textbooks and over 50 scholarly articles. He has assisted with structuring some of the largest acquisitions, investments and property deals in Vietnam, and he has won recognition for his outstanding practice, including “Best Tax Law Firm of the Year” and “Best Corporate Tax Law Firm” in Vietnam.
Vanderbruggen has provided training on tax treaty issues to government officials in a number of Southeast Asian countries, and has supplied expert testimony to tax courts on tax treaty interpretation.
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