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Pages: 512
Published: May 2006
ISBN: 978-90-76078-94-6
Order 2 or more books from the Doctoral Series and receive a 20% discount. Order 3 or more books and receive a 30% discount. The discount will be applied to the invoice.
No other discounts may be used in combination with this offer.
As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope. This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts. A comprehensive common framework of analysis, based on a checklist for governments, international organizations and taxpayers, is also developed in the study. |
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This framework lists the main advantages and disadvantages of treaty-related international income tax dispute resolution procedures. The checklist is formulated with the aim to assist readers in forming policies and in arguing positions, taking into account the subjective value given by each reader to each listed item.
The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
Before arriving at Harvard University, Dr Zvi D. Altman was an international tax advisor in Israel. He has published numerous articles in professional journals and newspapers, and has lectured extensively on international and domestic tax issues.During his stay at Harvard, Mr Altman held several teaching and fellowship positions. He is currently with the tax group of Sullivan & Cromwell LLP in New York.
About IBFD Academic Council
IBFD Doctoral Series is an initiative of IBFD Academic Council, a body established in 2000 to promote the discussion of international tax law at a high academic level and to stimulate the academic activities of IBFD. The Academic Council evaluates projects according to the sole criterion of their academic quality. Its members are appointed from among prominent academics and senior IBFD research staff members. Every thesis published in this series has been reviewed by the Academic Council to ensure that it is of a high quality.
Other books in the Doctoral Series:
- Vol. 1 - The Concept Of Income - A Multi-disciplinary Analysis
by Kevin Holmes - Vol. 2 - Taxing Portfolio Income in Global Financial Markets
by Doron Herman - Vol. 3 - Free Movement of Persons and Income Tax Law
by Prof. van Thiel - Vol. 4 - Advance Tax Rulings and Principles of Law
by Carlo Romano - Vol. 5 - Arbitration Under Tax Treaties
by Mario Züger - Vol. 6 - E-Commerce and Source-Based Income Taxation
by Dr Dale Pinto - Vol. 7 - Interpretation of Tax Treaties under International Law
by Dr Frank Engelen - Vol. 8 - Taxation of Investment Funds in the European Union
by Tomi Viitala - Vol. 9 - Taxation of Cross-Border Partnerships
by Dr Jesper Barenfeld - Vol. 10 - Taxation of International Performing Artistes
by Dr Dick Molenaar - Vol. 12 - Income from International Private Employment
by Frank Pötgens -
Vol. 13 - Taxation of Investment Derivatives
by Antti Laukkanen - Vol. 14 - International Tax Planning and Prevention of Abuse
by Luc De Broe
- Vol. 15 - EC Law Aspects of Hybrid Entities
by Gijs Fibbe
- Vol. 16 - EU VAT System and the Internal Market
by Rita de la Feria
by Stefan Mayer
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