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Current Tax Treaty Issues

This book presents a unique and detailed insight into the most controversial issues which may be found in the tax treaty context.
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Title:

Current Tax Treaty Issues

Subtitle:

50th Anniversary of the International Tax Group

Series:

Volume 18 in the EC and International Tax Law Series

Editor(s):
Guglielmo Maisto
Date of publication:
ISBN:

978-90-8722-596-4

Type of publication:

Print book

Number of pages:

728

Terms:

Shipping fees apply. View shipping information

Price:
EUR 130 / USD 155 (VAT excl.)
Order Print
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Title:

Current Tax Treaty Issues

Subtitle:

50th Anniversary of the International Tax Group

Series:

Volume 18 in the EC and International Tax Law Series

Editor(s):
Guglielmo Maisto
Date of publication:
ISBN:

978-90-8722-597-1

Type of publication:

eBook in ePub format

Number of pages:

728

Other:

Please note: Adobe Digital Editions is required

Read our eBook FAQ | Download sample

Price:
EUR 104 / USD 124 (VAT excl.)
Order eBook: ePub
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Title:

Current Tax Treaty Issues

Subtitle:

50th Anniversary of the International Tax Group

Series:

Volume 18 in the EC and International Tax Law Series

Editor(s):
Guglielmo Maisto
Date of publication:
ISBN:

978-90-8722-598-8

Type of publication:

eBook in PDF format

Number of pages:

728

Other:

This format has a fixed layout and is identical to the original print book. It is not possible to adjust font size, however, you can zoom in on a page or graphic.

Please note: Adobe Acrobat Reader is required

For further information see our eBook FAQ.

Price:
EUR 104 / USD 124 (VAT excl.)
Order eBook: PDF
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Title:

Current Tax Treaty Issues

Subtitle:

50th Anniversary of the International Tax Group

Series:

Volume 18 in the EC and International Tax Law Series

Editor(s):
Guglielmo Maisto
Date of publication:
ISBN:

978-90-8722-596-4

Type of publication:

Online book

Number of pages:

728

Terms:

Up to 5 users. View purchase information

Price:
EUR 130 / USD 155 (VAT excl.)
Order Online Book
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Current Tax Treaty Issues
Why this book?
Current Tax Treaty Issues – 50th Anniversary of the International Tax Group comprises contributions focusing on international tax issues marking the 50th anniversary of a group of experts whose collective writings for decades have landmarked the international literature on tax treaties and international tax law in general.
 
The book begins with a part on tax treaty policy and domestic law, including a review of the history of tax treaties and tax policy and international organizations in the tax treaty context. The domestic law aspects focus on a comparison of various features of tax litigation in the Netherlands and in the United Kingdom. It also includes an in-depth analysis of the “preservation principle” under which treaty provisions are prevented from being construed to restrict exclusions, exemptions, credit or other allowances granted by domestic law. Part 1 concludes with a review of the constitutional issues arising from the parliamentary process of approval of tax treaties.
 
Part 2 deals with treaty interpretation and application with a focus on tax treaty application to states and their political subdivisions and local authorities. It also includes a chapter on “treaty access” dealing with policy and practical considerations on access to treaties by commercial entities with a focus on the principal purpose test and the limitation on benefits provision and the handling of characterization issues under treaties. A separate chapter reviews the use of memoranda of understanding for tax treaty interpretation and administration for tax treaty interpretation. Part 2 concludes with an analysis of the use of the OECD Commentaries in the context of BEPS and the MLI.
 
Part 3 is devoted to taxing rules relating to the jurisdiction to tax, a commentary on the PE definition as revised by the 2017 Update to the Model Convention and the taxation of services income. It also analyses the treaty practice on article 21 of the OECD and UN Models. The definition of “beneficial ownership”, with the impact of the preamble to the 2017 Model Convention and the interpretation of the beneficial ownership limitation are also examined. Finally, a critique on the meaning of “beneficial ownership” before and after BEPS and whether the expression has become obsolete is presented.
 
This book presents a unique and detailed insight into the most controversial issues which may be found in the tax treaty context. As such, it is an essential reference source for international tax students, practitioners and academics.
 
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This book is part of the EC and International Tax Law Series
Contributor(s):
Stéphane Austry, John Avery Jones, Philip Baker, Peter H. Blessing, Robert J. Danon, Luc De Broe, Shefali Goradia, Johann Hattingh, Koichi Inoue, Guglielmo Maisto, Toshio Miyatake, Angelo Nikolakakis, Frank Pötgens, Kees van Raad, Richard Vann, Bertil Wiman
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