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Introduction to the Law of Double Taxation Conventions

Author: Michael Lang

Publisher: Linde Verlag GmbH

Published: 2021-04-01

Total Pages: 266

ISBN-13: 3709408628

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.

Introduction to the Law of Double Taxation Conventions

Author: M. Lang

Publisher:

Published: 2013

Total Pages: 0

ISBN-13: 9783709404546

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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 book provides an introduction to the law of double taxation conventions. Through examples from different countries and their jurisdictions, the book gives a global overview. 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 are also discussed in detail. Finally, the book analyses all provisions of the OECD and UN Model Tax Conventions on Income and on Capital and the OECD Model Convention on Estate, Inheritance and Gift Tax.

International Tax Policy and Double Tax Treaties

Author: Kevin Holmes

Publisher: IBFD

Published: 2007

Total Pages: 433

ISBN-13: 9087220235

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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.

The Effect of Treaties on Foreign Direct Investment

Author: Karl P Sauvant

Publisher: Oxford University Press

Published: 2009-03-27

Total Pages: 800

ISBN-13: 0199745188

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Over the past twenty years, foreign direct investments have spurred widespread liberalization of the foreign direct investment (FDI) regulatory framework. By opening up to foreign investors and encouraging FDI, which could result in increased capital and market access, many countries have improved the operational conditions for foreign affiliates and strengthened standards of treatment and protection. By assuring investors that their investment will be legally protected with closed bilateral investment treaties (BITs) and double taxation treaties (DTTs), this in turn creates greater interest in FDI.

Double Taxation and the League of Nations

Author: Sunita Jogarajan

Publisher: Cambridge University Press

Published: 2018-05-10

Total Pages: 425

ISBN-13: 1108381820

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Modern-day tax treaties have their foundations in one of the three Model Tax Treaties developed by the League of Nations in 1928. Using previously unexplored archival material, Sunita Jogarajan provides the first in-depth examination of the development of the League's Models. This new research provides insights into questions such as the importance of double taxation versus tax evasion; the preference for source-taxation versus residence-taxation; the influence of theory and practice on the League's work; the development of bilateral rather than multilateral treaties; the influence of developing countries on the League's work; the role of Commentary in interpreting model tax treaties; and the influential factors and key individuals involved. A better understanding of the development of the original models will inform and help guide interpretation and reform of modern-day tax treaties. Additionally, this book will be of interest to scholars of international relations and the development of law at international organisations.

International Double Taxation

Author: Mogens Rasmussen

Publisher: Kluwer Law International B.V.

Published: 2011-02-24

Total Pages: 240

ISBN-13: 9041137629

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A tax convention (or tax treaty) is an official agreement between two countries on the administration of taxation when the domestic tax legislation of the respective states applies simultaneously to a particular issue or taxpayer (e.g., when a taxpayer resident in one country derives income from sources in the other country). Tax conventions provide a means of settling on a uniform basis the most common problems that arise in the field of international double taxation. More than 2,000 bilateral tax treaties between countries of the world are based on the OECD (Organisation for Economic Cooperation and Development) Model Tax Convention. This book offers the reader a practical introduction to the law of income and capital tax conventions based on the OECD Convention as well as selected legislation and case law. It’s an ideal reference for lawyers and tax professionals who want to expand their familiarity with tax treaties.

Tax Treaty Case Law around the Globe 2021

Author: Georg Kofler

Publisher: Linde Verlag GmbH

Published: 2022-07-19

Total Pages: 332

ISBN-13: 3709412331

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A Global Overview of International Tax Disputes on DTC This book is a unique publication that gives a global overview of international tax disputes on double tax conventions and thereby fills a gap in the area of tax treaty case law. It covers the thirty most important tax treaty cases that were decided around the world in 2020. The systematic structure of each chapter allows for the easy and efficient study and comparison of the various methods adopted for applying and interpreting tax treaties in different cases. With the continuously increasing importance of tax treaties, "Tax Treaty Case Law around the Globe 2021" is a valuable reference tool for anyone interested in tax treaty case law. This book is of interest to tax practitioners, multinational businesses, policymakers, tax administrators, judges, and academics.

Klaus Vogel on Double Taxation Conventions

Author:

Publisher:

Published: 2015

Total Pages:

ISBN-13: 9789041160553

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International Law of Taxation

Author: Peter Hongler

Publisher: Oxford University Press

Published: 2021

Total Pages: 289

ISBN-13: 019289871X

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In this fresh, objective, and non-argumentative volume in the Elements of International Law series, Peter Hongler combines a comprehensive overview of the technical content of the international tax law regime with an assessment of its crucial relationship to wider international law. Beginning with an assessment of legal principles and foundations, the book considers key general principles, treaty based regimes, and regional integration in tax matters. In the second half of the work Hongler places international tax law in the context of its wider relationships with human rights law, and trade and investment law. He concludes by considering major legal successes and failures and what might be done to address these.

The Legal Status of the OECD Commentaries

Author: Sjoerd Douma

Publisher: IBFD

Published: 2008

Total Pages: 284

ISBN-13: 9087220278

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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.