Using The Oecd Model Commentaries And Other Tools To Interpret Tax Treaties
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Author | : C.A. Theophilou |
Publisher | : |
Total Pages | : |
Release | : 2019 |
Genre | : |
ISBN | : |
Download Using the OECD Model Commentaries and Other Tools to Interpret Tax Treaties Book in PDF, Epub and Kindle
In this article, the author discusses the interpretation of tax treaties and the use of internal and external tools as interpretive aids. In particular, he considers whether it is appropriate to rely on the commentaries to the OECD model income tax treaty as an external tool and examines the availability of established internal aids for treaty interpretation.
Author | : Carlo Garbarino |
Publisher | : Edward Elgar Publishing |
Total Pages | : 699 |
Release | : 2016-10-28 |
Genre | : Business & Economics |
ISBN | : 1785365886 |
Download Judicial Interpretation of Tax Treaties Book in PDF, Epub and Kindle
Judicial Interpretation of Tax Treaties is a detailed analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, the book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book operates on two levels: firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 658 |
Release | : 2017-12-18 |
Genre | : |
ISBN | : 9264287957 |
Download Model Tax Convention on Income and on Capital: Condensed Version 2017 Book in PDF, Epub and Kindle
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...
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 2624 |
Release | : 2019-04-25 |
Genre | : |
ISBN | : 9264306994 |
Download Model Tax Convention on Income and on Capital 2017 (Full Version) Book in PDF, Epub and Kindle
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, ...
Author | : Sjoerd Douma |
Publisher | : IBFD |
Total Pages | : 284 |
Release | : 2008 |
Genre | : Double taxation |
ISBN | : 9087220278 |
Download The Legal Status of the OECD Commentaries Book in PDF, Epub and Kindle
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.
Author | : |
Publisher | : |
Total Pages | : 350 |
Release | : 2005-01-01 |
Genre | : Double imposition - Conventions - Interprétation |
ISBN | : 9780968655344 |
Download The Interpretation of Income Tax Treaties with Particular Reference to the Commentaries on the OECD Model Book in PDF, Epub and Kindle
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 2289 |
Release | : 2015-10-30 |
Genre | : |
ISBN | : 9264239081 |
Download Model Tax Convention on Income and on Capital 2014 (Full Version) Book in PDF, Epub and Kindle
This publication is the ninth 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 on Income and on Capital as it read on 15 July 2014.
Author | : Michael Lang |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 402 |
Release | : 2001-12-19 |
Genre | : Business & Economics |
ISBN | : 9041198571 |
Download Tax Treaty Interpretation Book in PDF, Epub and Kindle
Detailed survey of tax treaty interpretations in 16 European countries taking into account court decisions since 1993, the OECD reports on partnership, changes in administrative practice at national level and recent Community law effecting taxation and tax practice.
Author | : Thomas Ecker |
Publisher | : |
Total Pages | : 734 |
Release | : 2011 |
Genre | : Double taxation |
ISBN | : 9783707320114 |
Download History of Tax Treaties Book in PDF, Epub and Kindle
This book provides an historical in-depth analysis for each provision in the OECD MC. It offers a refurbished presentation of the history and internal processes of the international organizations involved in the tax treaty models' development. This historical analysis helps the reader understand the design and content of certain provisions, as well as their role in the system as a whole. As such, the value of an historical analysis goes far beyond mere understanding of the past: it also provides tools for interpretation. By using those tools, one can solve numerous current interpretation issues and gain new insights for future improvements of the OECD MC.
Author | : Richard Xenophon Resch |
Publisher | : Tredition Gmbh |
Total Pages | : 288 |
Release | : 2020-05-05 |
Genre | : |
ISBN | : 9783347058835 |
Download Tax Treaty Interpretation Book in PDF, Epub and Kindle
This study clarifies the meaning and application of Article 3(2) of the OECD Model Tax Convention on Income and on Capital. It maps the entire historical debate on the provision, illuminates flawed assumptions and misunderstandings in its course, and outlines how these continue to fuel the current controversies. In addition, it provides a comprehensive analysis of German case law concerning the interpretation of tax treaties and examines the extent to which the German Federal Fiscal Court has been influenced by views developed in doctrine. Finally, it clarifies the relationship between Article 3(2) and the rules on treaty interpretation codified in the Vienna Convention on the Law of Treaties, the meaning of 'context', and how the condition 'unless the context otherwise requires' is to be applied. Thereby, an approach is submitted that is firmly based on public international law principles and transcends the current controversies into a holistic synthesis.