Use this URL to cite or link to this record in EThOS:
Title: Taxation of income of international transportation companies
Author: Üzeltürk, Hakan
Awarding Body: University of Edinburgh
Current Institution: University of Edinburgh
Date of Award: 1998
Availability of Full Text:
Access from EThOS:
Full text unavailable from EThOS. Please try the link below.
Access from Institution:
The thesis is divided into three parts. Following the introduction, Part I deals with the character of international double taxation, how it occurs, taxation principles and historical developments. There follows a review of the various methods of preventing international double taxation under three categories - unilaterally, bilaterally and multilaterally. Also, information about double taxation agreements is provided including definitions, functions, types, historical background with the role of international organisations and interpretation. Part II of the thesis includes four chapters, one for each sample country, dealing with their national systems in the field of international transportation with related legislation and cases. Part III, under the heading of international transportation income deals with the problems of international transportation, within the context of two common double taxation Models, the OECD and the United Nations Model, as well as the United States Model. Furthermore, the positions regarding the four sample countries - Canada, Turkey, the United Kingdom and the United States - with double taxation agreements concerning international transportation are examined in the light of the OECD, the United Nations and the United States Model. After a comprehensive examination of some important topics related with international transportation including the concept of "having a trade or business", the determination of residence for international transportation companies, the concept of the term "permanent establishment", the allocation of international transportation income between different jurisdictions, reciprocal exemption of international transportation income between countries and the difficulties arising from flags of convenience, an attempt is made to offer possible solutions.
Supervisor: Not available Sponsor: Not available
Qualification Name: Thesis (Ph.D.) Qualification Level: Doctoral
EThOS ID:  DOI: Not available