in-print-bilateral-benefits-0409-en

Thisquestionraisestwofundamentalissues1whetherthe

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Unformatted text preview: erland for the avoidance of Double Taxation with respect to Taxes on income, signed at Washington on October 2, 1996 (herein referred to as “the us-switzerland treaty”). However, paragraph 7 of the memorandum of understanding to the us-switzerland treaty, signed on May 14, 1997 and before entry into force, permits more comprehensive derivative benefits. 48 see article 21(3) of the Convention between the government of the united states of america and belgium for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on income, signed at brussels on November 27, 2006, as amended by the protocol signed on November 27, 2006; article 22(3) of the Convention between the government of the united states of america and Denmark for the avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on income, signed at Washington on august 19, 1999, as amended by the protocol signed at Copenhagen on May 2, 2006; article 16(3) of the Conve...
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