Multilateral Tax Treaties
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Multilateral Tax Treaties
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Author : Helmut Loukota
language : en
Publisher: Kluwer Law International B.V.
Release Date : 1998-04-22
Multilateral Tax Treaties written by Helmut Loukota and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998-04-22 with Business & Economics categories.
The book is a result of a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project's aim was to produce a draft multilateral tax treaty modelled on the OECD Model Income Tax Convention, whilst examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a detailed analysis of the arguments for and against the conclusion of a multilateral tax treaty, and of the various European law issues that arise in this context.
A Multilateral Convention For Tax
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Author : Sergio André Rocha
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-11-29
A Multilateral Convention For Tax written by Sergio André Rocha and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-11-29 with Law categories.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.
The Oecd Multilateral Instrument For Tax Treaties
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Author : Michael Lang
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
The Oecd Multilateral Instrument For Tax Treaties written by Michael Lang and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-04-24 with Law categories.
The Multilateral Instrument (MLI) proposed in OECD BEPS Action 15 will lead to the modification of numerous tax treaties. As tax treaties can have different wording, terminology and structure, a great challenge is to find a proper way to accomplish their modification without distorting the underlying framework or triggering undesirable effects. This book analyses the MLI, which was signed by over seventy jurisdictions on 7 June 2017. The topics covered include: • the procedural mechanisms on how the new measures to prevent base erosion and profit shifting (BEPS) will interact with and complement existing tax treaties; • the scope of the MLI in order to ascertain which tax treaties and taxes are covered; • the interpretation of terms used in the MLI and the relationship between the languages used in the MLI and in the particular tax treaties; • the implementation of the minimum standard through the MLI, as well as how states can exercise various options offered by the MLI and reserve the right not to apply certain provisions of the MLI; • the legal consequences of the exercise of options and reservations for the other states; • the notification procedure through which states declare their choices; and • the possibilities and procedure for withdrawal from the obligations entered into upon signing the MLI. Finally, the book discusses whether the mechanism of the MLI can serve as a role model for future changes to the OECD Model Convention. The book incorporates the analyses of leading scholars and practitioners dealing with international tax matters. Critical insights are offered for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.
Multilateral Instrument For Updating The Tax Treaty Network
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Author : NATHALIE. BRAVO
language : en
Publisher:
Release Date : 2020
Multilateral Instrument For Updating The Tax Treaty Network written by NATHALIE. BRAVO and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020 with categories.
Looking Ahead Inter National Law In 21st
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Author : D.M. Broekhuijsen
language : en
Publisher: Springer
Release Date : 2002-03-21
Looking Ahead Inter National Law In 21st written by D.M. Broekhuijsen and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002-03-21 with Law categories.
Many states have set out to develop a multilateral tax instrument with the purpose of amending bilateral treaties in a quick and comprehensive fashion. The recent adoption by as many as a hundred jurisdictions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the OECD Multilateral Instrument) is the most prominent step in this direction. This book provides not only a detailed analysis of the OECD Multilateral Instrument but also discusses in depth the far-reaching implications of the international tax reform currently under way. The author shows how the BEPS Project has merely unveiled the problems related to bilateral tax relationships and articulates initiatives to ensure the sustainability of a multilateral consensus. Drawing on the fields of international law, international relations, and political science, he develops a design strategy, complete with draft clauses, that fundamentally transforms the way states cooperate in the field of international tax, effectively addressing such problems as the following: – the need for collective action; – the problem structure of multilateral tax cooperation; – the relevance of the OECD Model Tax Convention and Commentaries thereon; – the place, position and operation of the OECD Multilateral Instrument; – non-OECD member countries; and – treaty shopping. The principled and pragmatic structural solution presented would allow policymakers to continuously adapt and respond to the rapidly evolving nature of the global economy. The author’s original research and his recommendations for future development of the topic offer deeply informed guidance to policymakers, practitioners and other tax professionals, and academics.
Mli Made Easy
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Author : Kuldeep Sharma
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2021-04-22
Mli Made Easy written by Kuldeep Sharma and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-04-22 with Law categories.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) provides an innovative approach to enable countries to swiftly modify their bilateral tax treaties in order to implement measures developed in the course of the Base Erosion and Profit Shifting (BEPS) Project. MLI, the first successfully concluded multilateral tax treaty, provides jurisdictions with the tools they need to ensure that profits are taxed where economic activities generating the profits are performed, while at the same time giving businesses greater certainty. MLI Made Easy makes it easier to get a complete grasp of this swift but complex modification process of tax treaties. This first and only self-contained book offers an unmatched article-by-article discussion of the MLI with an abundance of practical examples, diagrams, and flowcharts to make the information easier to understand and apply. Focusing on measures to combat tax evasion and abuse of tax treaties arising due to artificial avoidance of a permanent establishment status, hybrid mismatch arrangements, and other aspects of taxation, the book includes an in-depth discussion of the following and more: how specific gaps in existing bilateral tax treaties are addressed by the MLI; positions taken by selected jurisdictions and their impact on treaties; compatibility clauses, notification clauses, opting-in mechanisms, alternative provisions, and reservations; experiences in the course of implementation of the MLI; misconceptions and lingering doubts in respect of various substantive and procedural provisions of the MLI; interaction between the principal purpose test and simplified limitation on benefits; improving dispute resolution; and meaning of the phrases ‘on or after’, ‘other taxes’, and interpretational issues in entry into effect provisions. Adopted by a majority of jurisdictions worldwide, MLI preserves the tax sovereignty of its Parties and has been successful in overcoming barriers to the conclusion of a worldwide multilateral tax treaty. Because this easy-to-use book immensely facilitates understanding and application of the treaty measures developed in the course of the BEPS Project, it will be of immeasurable use to practitioners and other professionals engaging in international taxation, as well as to taxation authorities and interested academics in any part of the world.
Developing A Multilateral Instrument To Modify Bilateral Tax Treaties
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Author : OCDE,
language : en
Publisher: OCDE
Release Date : 2015-10-20
Developing A Multilateral Instrument To Modify Bilateral Tax Treaties written by OCDE, and has been published by OCDE this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-10-20 with Double taxation categories.
Drawing on the expertise of public international law and tax experts, this report explores the technical feasibility to develop a multilateral instrument to modify tax treaties so as to efficiently implement the tax treaty-related BEPS measures. The report concludes that such an instrument is desirable and feasible and that negotiations for the multilateral instrument should be convened quickly. Based on this analysis, a mandate has been developed for an ad-hoc group, open to the participation of all countries on an equal footing, to develop the multilateral instrument and open it for signature in 2016.
The Nordic Multilateral Tax Treaty As A Model For A Multilateral Eu Tax Treaty
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Author : Marjaana Helminen
language : en
Publisher:
Release Date : 2013
The Nordic Multilateral Tax Treaty As A Model For A Multilateral Eu Tax Treaty written by Marjaana Helminen and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with categories.
The Impact Of Community Law On Tax Treaties Issues And Solutions
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Author : Pasquale Pistone
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2002-03-11
The Impact Of Community Law On Tax Treaties Issues And Solutions written by Pasquale Pistone and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002-03-11 with Business & Economics categories.
Study on the question of harmonization of direct taxation among European Community Member States: how Member States must comply with EC Law as they apply their tax treaties, how EC law regulates cross-border tax issues within the Community, and how EC law affects tax treaties between EU Member States and third countries. The book provides expert commentary on 27 leading tax cases from the European Court of Justice, and gives the proposal of EC Model Tax Convention, which combines existing provisions of international tax law with the principles of Community tax law.
A Multilateral Tax Treaty
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Author : Dirk M. Broekhuijsen
language : en
Publisher:
Release Date : 2018-03
A Multilateral Tax Treaty written by Dirk M. Broekhuijsen and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-03 with Law categories.
Many states have set out to develop a multilateral tax instrument with the purpose of amending bilateral treaties in a quick and comprehensive fashion. The recent adoption by as many as a hundred jurisdictions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the OECD Multilateral Instrument) is the most prominent step in this direction. This book provides not only a detailed analysis of the OECD Multilateral Instrument but also discusses in depth the far-reaching implications of the international tax reform currently under way. The author shows how the BEPS Project has merely unveiled the problems related to bilateral tax relationships and articulates initiatives to ensure the sustainability of a multilateral consensus. Drawing on the fields of international law, international relations, and political science, he develops a design strategy, complete with draft clauses, that fundamentally transforms the way states cooperate in the field of international tax, effectively addressing such problems as the following: - the need for collective action; - the problem structure of multilateral tax cooperation; - the relevance of the OECD Model Tax Convention and Commentaries thereon; - the place, position and operation of the OECD Multilateral Instrument; - non-OECD member countries; and - treaty shopping. The principled and pragmatic structural solution presented would allow policymakers to continuously adapt and respond to the rapidly evolving nature of the global economy. The author's original research and his recommendations for future development of the topic offer deeply informed guidance to policymakers, practitioners and other tax professionals, and academics.