| Autor: |
Jones, John F. Avery |
| Předmět: |
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| Zdroj: |
British Tax Review; 2013, Vol. 2013 Issue 1, p9-15, 7p |
| Abstrakt: |
The article discusses an applicability of the "subject to tax" clause with reference to the court case Weiser v. HMRC, in which a resident of Israel was exempted from tax. It informs that the subject to tax clause is not a solution because it prevents pension funds and charities from obtaining treaty funds. It discusses that beneficial owner may be substituted for subject to tax, which would be excluding nominees and including pension funds and charities. |
| Databáze: |
Supplemental Index |
| Externí odkaz: |
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