International taxation of cross-border leasing income

Thesis

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Titlepage

FOREWORD

TABLE OF CONTENTS

CHAPTER 1 INTRODUCTION

CHAPTER 2 TRANSACTION/LEASE CHARACTERIZATION ASPECTS

CHAPTER 3 DEPRECIATION/CAPITAL ALLOWANCES ASPECTS

CHAPTER 4 INCOME RECOGNITION ASPECTS

CHAPTER 5 LIMITS OF TAX-DRIVEN CROSS-BORDER LEASING TRANSACTIONS

CHAPTER 6 TAX TREATY IMPLICATIONS OF LEASE INCOME CHARACTERIZATION

CHAPTER 7 TAX TREATY ASPECTS OF TAXATION OF CROSS-BORDER LEASING INCOME IN THE SOURCE STATE

CHAPTER 8 RELEVANCE OF THE EC TREATY (CROSS-BORDER LEASING BETWEEN THE EC MEMBER STATES)

CHAPTER 9 SUMMARY, CONCLUSIONS AND RECOMMENDATIONS

APPENDIX 1 US CASE LAW ON LEASE V.CONDITIONAL SALE

APPENDIX 2 SPECIAL AND ACCELERATED DEPRECIATION IN JAPAN*

APPENDIX 3 TAX TREATIES EXAMINED FOR THE PURPOSES OF THIS STUDY

APPENDIX 4 ECJ CASES EXAMINED FOR ASCERTAINING ARGUMENTS ADAVNACED BY THE MEMBER STATES TO JUSTIFY RESTRICTIVE PROVISIONS UNDER THE NATIONAL DIRECT TAX LAWS

BIBLIOGRAPHY

TABLE OF CASE LAW

DUTCH SUMMARY

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