31 results on '"Miyatake, Toshio"'
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2. Chapter 11 Japan
3. The definitions of dividends and interest in the OECD model: something lost in translation?
4. Japanese transfer pricing taxation.
5. Dual Residence of Companies under Tax Treaties
6. The origins of concepts and expressions used in the OECD model and their adoption by states.
7. Treaty conflicts in categorising income as business profits caused by differences in approach between common law and civil law.
8. Characterisation of other states' partnerships for income tax.
9. Taxation caused by or after a change in residence.
10. The definition of dividend in the double taxation relief article.
11. Tax treaty problems relating to source.
12. Tax treaty problems relating to source
13. Credit and exemption under tax treaties in cases of differing income characterisation.
14. A resident of a contracting state for tax treaty purposes: a case comment on Crown Forest Industries.
15. Transfer pricing: U.S. and Japanese views.
16. The other income article of income tax treaties.
17. Tax Treaty Disputes in Japan
18. Transfer pricing disputes in Japan
19. Tax Treaty Disputes in Japan
20. Interpretation of article 15(2)(b) of the OECD model convention: 'remuneration paid by, or on behalf of, an employer who is not a resident of the other state'
21. Taxation of non resident artistes and athletes: a comparative analysis: Japan
22. The interpretation of tax treaties with particular reference to Article 3(2) of the OECD model - II.
23. The business purpose test and abuse of rights.
24. The legal nature of the mutual agreement procedure under the OECD Model Convention - II.
25. Dual residence of individuals: the meaning of the expressions in OECD Model Convention - I.
26. Laminar Strength of GFRP under Combined Axial and Shear Loadings
27. A New Probing System for Testing LSIs by Applying a Silicon Micromachining Technique.
28. Strengths of GFRP under Combined Compressive and Shear Loading
29. Shear/Compressive Strength cf GFRP Under Mixed Load Condition at Low Temperature.
30. Japan.
31. Article 24(5) of the OECD Model in Relation to Intra-group Transfers of Assets and Profits and Losses.
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