Interpretation of tax law and treaties and transfer pricing in Japan and Germany
著者
書誌事項
Interpretation of tax law and treaties and transfer pricing in Japan and Germany
（Series on international taxation, 20）
Kluwer Law International, 1998
大学図書館所蔵 件 / 全25件
-
該当する所蔵館はありません
- すべての絞り込み条件を解除する
注記
Includes bibliographical references and index
内容説明・目次
内容説明
This work is the result of a conference held in September 1996 in Germany in honour of Professor Hiroshi Kaneko, Emeritus Professor of Tokyo State University. Some 60 scholars and practitioners of international tax law from Japan and Germany convened to discuss questions of common interest. The first part of the book explores the methods of interpretation of tax statutes and treaties used in both countries, particularly in light of the totally different structure of the Japanese language as compared to European languages. Such differences may be of potentially significant importance to the interpretation of tax treaties, usually concluded in two authentic language versions which are equally binding. The papers in the second part present a detailed analysis of issues of international transfer pricing in Germany and in Japan, highlighting important differences as well as surprising similarities of the two legal systems. The collection of expert papers provides an important contribution to the literature in the field of international and comparative taxation.
For the tax practitioner it should be useful reading when he or she is confronted with Japanese tax treaties, the interpretation of which is contested, or with transfer pricing problems in connection with Japan.
目次
- Interpretation of Law in Japan in the Light of Comparison with Common Law Systems
- K. Kimura. Observation
- A. Wani. Statutory Interpretation as a Process of Tax Law-Making: The Case of Japan
- Y. Masui. Interpretation of Tax Statutes in Japan
- M. Iwasaki. Interpretation of Tax Law by Tutatu (Japanese Ruling)
- F. Tamakuni. Statement
- M. Shibuya. General Rules of Statute Interpretation in Germany
- J. Lang. Interpretation of Tax Statutes in Germany
- W. Schon. Comments on Wolfgang Schon, Interpretation of Tax Statutes in Germany
- L. Osterloh. Interpretation of Tax Treaties According to German Theory and Practice
- M. Lehner. Does It Make Sense if We Speak of an `International Tax Language'? R. Prokisch. Interpretation of Tax Treaties in Japan
- T. Murai. Comments on the Report by Professor Tadashi Murai, Interpretation of Tax Treaties in Japan
- H. Urahigashi. Comments on the Interpretation of Tax Treaties: The Intertwinement of Tax Treaties with Domestic Tax Law in Japan
- S. Taniguchi. Discussion. The Examination of Transfer Pricing by the German Tax Administration: Rules and Practice
- H.-D. Hoppner. Transfer Pricing: The Japanese Perspective
- M. Nakazato. Comments on the General Rule of Transfer Taxation
- N. Yoshimura. International Transfer Pricing Disputes: Some Comment on the Main Reports
- Y. Kawabata. Transfer Pricing Taxation on Intangible Property in Japan
- F. Komamiya. Transfer Pricing on Intangible Property in Germany
- H. Zitzelsberger. Comments on the Presentations of Professors Komamiya and Zitzelsberger
- M. Nakazato. The Need for Mandatory Arbitration Proceedings for the Resolution of Transfer Pricing Disputes
- K. Sieker. Discussion. Advance Pricing Agreements, Mutual Agreements and Arbitration in Japan
- T. Mizuno. Advance Pricing Agreements in the USA and in Germany
- A. Radler. Statement Concerning Advanced Pricing Agreements
- U. Moebus. Discussion.
「Nielsen BookData」 より