Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties
Bibliographic record
Abstract
Why this book? Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties, comprising the proceedings and working documents of an annual seminar held in Milan in November 2016, is a detailed and comprehensive study on the taxation of highly transnational industries engaged in the shipping and air transport sectors. It begins with a comparative analysis of the domestic regulatory and tax regimes of such industries and then examines the influence of EU law on national law, with a particular emphasis on the jurisprudence of the Court of Justice of the European Union on tonnage taxation systems and VAT regimes. The book then moves to selected tax treaty issues. In particular, it analyses: (i) the historical background and the proposed changes to articles 8 and 15(3) of the OECD Model Convention; (ii) the recent developments concerning article 8 of the OECD Model Convention and the application of the place of effective management criterion, instead of the residence criterion, as connecting factor; (iii) the most relevant tax treaty issues related to the qualification, allocation and apportionment of income derived by shipping and air transport activities; and (iv) the taxation of the remuneration of crews of ships and aircraft. Individual country surveys provide an in-depth analysis of the domestic tax regimes and actual tax treaty application and practices of various states, including Australia, Austria, Brazil, Canada, China and Hong Kong, Denmark, Germany, Greece, Italy, Liberia, the Netherlands, Spain, Switzerland and the United Kingdom. This book presents a unique and detailed insight into the taxation of shipping and air transport activities in an international context and is therefore an essential reference source for international tax students, practitioners and academics. Downloads Sample excerpt, including table of contents This book is part of the EC and International Tax Law Series View other titles in the series Editor(s) Guglielmo Maisto Contributor(s) Haroun Asghar, Raphaël Baeriswyl, Clive M. Baxter, Silvia Boiardi, James R. Border, Micah Burch, Jérôme Bürgisser, Giancarlo Chamma Matarazzo, Elena E.N. Christensen, Theophilus Dekonty Joseph, Michael P. Hansen, Alexander Hemmelrath, Katarina Johannessen, Georg Kofler, Zigurds G. Kronbergs, John J. Lennard, Na Li, Lars Marquardsen, Stefan Maunz, Taco Mooren, Tiago Moreira Vieira Rocha, Ana Pita Grandal, Frank P.G. Pötgens, Isabelle Richelle, Carmen Ruiz Hidalgo, Jacques Sasseville, Ton Stevens, Michail Tegos, Trine Thomsen, Maurits van de Sande, Mees M. Vergouwen, Dennis Weber, Christiane Zöhrer
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.003 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.001 | 0.003 |
| Scholarly communication | 0.006 | 0.005 |
| Open science | 0.001 | 0.001 |
| Research integrity | 0.002 | 0.003 |
| Insufficient payload (model declined to judge) | 0.004 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".