The Impact Of The Oecd And Un Model Conventions On Bilateral Tax Treaties
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The Impact Of The Oecd And Un Model Conventions On Bilateral Tax Treaties
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Author : Michael Lang
language : en
Publisher: Cambridge University Press
Release Date : 2012-05-17
The Impact Of The Oecd And Un Model Conventions On Bilateral Tax Treaties written by Michael Lang and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-05-17 with Law categories.
This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions from five continents and empirically ascertains the impact of the UN and OECD Model Tax Conventions on bilateral tax treaties. It therefore fills a major gap in the international tax literature, which has so far either studied the sole Model Tax Conventions or focused on bilateral treaties in the context of the tax treaty policy of single countries, and sets the pace for a new methodology in the analysis and interpretation of tax treaties. A general report outlines the key points of the analysis, highlights current trends and predicts future developments of multilateralism and global tax law. This is an essential resource for academics, tax authorities and international tax practitioners who find textbooks based on Model Tax Conventions insufficient.
Model Tax Convention On Income And On Capital Condensed Version 2017
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2017-12-18
Model Tax Convention On Income And On Capital Condensed Version 2017 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-12-18 with categories.
This is the tenth edition of the condensed version of the "OECD Model Tax Convention on Income and on Capital". It contains the full text of the "Model Tax Convention on Income and Capital" as it read on 21 November 2017, but without the historical notes and the background reports included...
The Legal Status Of The Oecd Commentaries
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Author : Sjoerd Douma
language : en
Publisher: IBFD
Release Date : 2008
The Legal Status Of The Oecd Commentaries written by Sjoerd Douma and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Double taxation categories.
Since the mid-1980s, the legal basis of the practice of tax administrations and courts around the world to conform to the Commentaries when interpreting and applying bilateral tax treaties based on the OECD Model has been the subject of an ongoing academic debate. Recently the debate has received new impetus, and the primary focus is now on the general principles of international law. In particular, opinions differ on the question whether the Commentaries can be a source of legal obligations through the principles of acquiescence and estoppel, both of which are founded on considerations of good faith, and equity and provide specific protection of settled expectations. The reports contained in this book address two questions. The first is whether, under international law, the states parties to a tax treaty are legally bound by the OECD Commentaries when interpreting and applying the provisions of the treaty which are identical to those of the OECD Model. The second question is whether, under the contracting states' internal law, taxpayers and the tax authorities are equally bound to apply the Commentaries if and when the contracting states themselves are so bound under international law. The book brings various legal disciplines - public international law, international tax law, Community law and constitutional law - together in order to resolve the legal status of the Commentaries. Through interdisciplinary debate, the issues have been defined clearly and the exact points at which the opinions differ are identified, thereby resulting in a better understanding of the issues at hand.
The Un Model Convention And Its Relevance For The Global Tax Treaty Network
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Author : Michael Lang
language : en
Publisher:
Release Date : 2013
The Un Model Convention And Its Relevance For The Global Tax Treaty Network written by Michael Lang 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.
As almost every income tax treaty is based on precedents found in the OECD or UN Model Convention, the practical relevance of the two Models is undeniable. The Models and the Commentaries thereon serve not only as starting points during treaty negotiations but also as significant aids in interpretation in the sense of articles 31 and 32 of the Vienna Convention on the Law of Treaties. Although the UN Model draws strongly from the OECD Model, it pursues a different aim and deviates substantially in certain provisions.0In its 11 chapters, this book provides a detailed analysis of the deviations between the OECD and UN Models. It examines the provisions included in the Models, as well as their impact and relevance.0The book incorporates the perspectives of leading scholars and practitioners in the field of international taxation.
Model Tax Convention On Income And On Capital 2017 Full Version
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2019-04-25
Model Tax Convention On Income And On Capital 2017 Full Version written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2019-04-25 with categories.
This publication is the tenth edition of the full version of the OECD Model Tax Convention on Income and on Capital. This full version contains the full text of the Model Tax Convention as it read on 21 November 2017, including the Articles, Commentaries, non-member economies’ positions, ...
International Tax Policy And Double Tax Treaties
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Author : Kevin Holmes
language : en
Publisher: IBFD
Release Date : 2007
International Tax Policy And Double Tax Treaties written by Kevin Holmes and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Double taxation categories.
Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice operate to ultimately impose tax on international business and investment.
Other Income Under Tax Treaties
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Author : Alexander Bosman
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2015-09-23
Other Income Under Tax Treaties written by Alexander Bosman 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 2015-09-23 with Law categories.
Bilateral tax treaties are often, to a greater or lesser extent, based on the OECD Model Convention. Among the distributive rules with respect to taxation of income which are laid down in Chapter III of that model, Article 21 assigns the tax jurisdiction in respect of "other income" - understood to mean items of income which are not dealt with in other provisions of the tax treaty - to the residence state in accordance with the main rule underlying the OECD Model, thus ensuring that no income falls outside the scope of the treaty. This study provides a comprehensive analysis of Article 21 of the OECD Model. In extensive detail, and with reference to case law from a number of jurisdictions and to statements of various authorities and official documents, the author shows how Article 21 operates in relation to the other distributive rules of the OECD Model and bilateral tax treaties based thereon. The analysis considers such items of income as the following in relation to Article 21: - income from immovable property; - business profits; - profits from shipping, inland waterways transport, and air transport; - dividends, interest, and royalties; - capital gains; and - income from employment. In addition, the author examines the significance of the OECD Commentaries for the interpretation of tax treaties, the "other income" article in other model conventions, and notable deviations from Article 21 among bilateral tax treaties. An appendix offers well-grounded recommendations on how to potentially amend the wording of Article 21 and the related commentary and how the application of the article can be improved. Although underexposed in the tax law literature heretofore, the "other income" article raises important international taxation issues that remain problematic or unresolved. Tax lawyers, government officials, and other interested professionals will find here a penetrating analysis that goes a long way towards clarifying the characterisation of income that resists the standard categories defined in tax treaties.
Model Tax Convention On Income And On Capital Condensed Version 2003
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 2003-01-20
Model Tax Convention On Income And On Capital Condensed Version 2003 written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2003-01-20 with categories.
This publication is the condensed version of the OECD Model Tax Convention on Income and on Capital, produced in a loose-leaf format to accommodate yearly updates. This fifth edition contains the full text of the Model Tax Convention as it read on 28 January 2003, but without the historical notes.
Introduction To The Law Of Double Taxation Conventions
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2021-04-01
Introduction To The Law Of Double Taxation Conventions written by Michael Lang and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-04-01 with Law categories.
The Law of Double Taxation Conventions Cross-border activities or transactions may trigger tax liability in two or more jurisdictions. In order to mitigate the financial burden resulting from these situations, States have entered into numerous double taxation conventions, which provide for rules that allocate the taxing rights between the contracting states. This handbook aims at providing an introduction to the law of double taxation conventions. It is designed for students – irrespective of their national background, but the author believes that it will also be of great help for tax experts who wish to know more about double taxation conventions, as well as for international law experts who wish to understand more about tax law. The handbook does not consider one jurisdiction in particular but rather takes examples from a wide range of different countries and their jurisdictions. It includes an overview of the problem of double taxation, the state practice in the conclusion of double tax conventions and their effects, the interpretation of double taxation conventions and treaty abuse. Furthermore, this updated handbook takes new developments into account occurred since the last edition of the book from 2013, in particular also the changes through OECD’s BEPS project and the Multilateral Instrument. It deals with the latest versions of the OECD Model Tax Conventions on Income and on Capital and the UN Model Double Taxation Convention between Developed and Developing Countries, both published in 2017, as well as the latest version of the OECD Model Double Taxation Convention on Estates and Inheritances and on Gifts.
Issues In International Taxation The Application Of The Oecd Model Tax Convention To Partnerships
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Author : OECD
language : en
Publisher: OECD Publishing
Release Date : 1999-08-26
Issues In International Taxation The Application Of The Oecd Model Tax Convention To Partnerships written by OECD and has been published by OECD Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 1999-08-26 with categories.
This report addresses the issue of the application of tax treaties to cases involving partnerships in detail and focuses on specific factual examples.