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Global Tax Treaty Commentaries

Analytical commentaries on OECD and UN model provisions, drawing on actual tax treaty practice and country interpretations of the model provisions and their many common variations.

 

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Title:

Global Tax Treaty Commentaries

Editor(s):
Richard Vann (Editor-in-Chief) et al
Date of publication:
ISBN:

978-90-8722-250-5

Type of publication:

Online collection

Access:

Up to five users. View purchase information

Price:
Available on request
Enquire / Order via Email
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  • IBFD Members are eligible for a 20% discount.
  • Global Tax Explorer (Plus) subscribers are eligible for a 10% discount
Global Tax Treaty Commentaries
Why subscribe?
The IBFD Global Tax Treaty Commentaries (GTTC) is the authoritative source for analysis and commentary of tax treaty practices across the globe. This peer-reviewed cutting edge publication is authored by world-class academics and tax professionals.

As theory and practice do not always coincide, this publication covers not only the model conventions, but also the most important variations as well as the diverging national tax treaty policies. The commentaries are based on the perspectives of internationally renowned experts on each article with input from tax treaty experts from over 20 countries. GTTC gives a complete picture of the realities of everyday international tax treaty practice and also includes recent instruments such as tax information exchange agreements (TIEAs).

GTTC will eventually consist of 27 chapters, each dedicated to one of the articles of the OECD Model and 8 chapters on important meta-topics relating to the models and tax treaties in general, including “Treaty Interpretation”, “Non-Discrimination” and “Conflicts of Qualification”. By weaving all these aspects together, in combination with seamless links to the IBFD Tax Research Platform, IBFD offers tax practitioners – from the advisory and corporate sector, government and the judiciary, treaty negotiation and academic departments – a rich tapestry of information unmatched by any existing product.
 
 
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Main Contents

 

IBFD Global Tax Treaty Commentaries currently contains the following chapters:

  • General Introduction – Global Tax Treaty Commentaries: Prof. Richard Vann (Australia)
  • Article 2: “Taxes Covered”: Prof. Wei Cui (Canada)
  • Article 4: “Resident”: Belema R. Obuoforibo
  • Article 5: “Permanent Establishment”: Prof. Brian Arnold (Canada)
  • Article 6: “Immovable Property”: Danil V. Vinnitskiy
  • Article 7: “Business Profits”: Prof. Jacques Sasseville (France) and Prof. Richard Vann (Australia)
  • Article 8: “International Transport and Other Operations”: Prof. Guglielmo Maisto (Italy)
  • Article 9: “Associated Enterprises”: Eduardo Baistrocchi
  • Article 10: “Dividends”: Prof. Peter A. Harris (United Kingdom)
  • Article 11: “Interest”: Prof. Marjaana Helminen (Finland)
  • Article 12: “Royalties”: Prof. Adolfo Martín Jiménez (Spain)
  • Article 13: “Capital Gains”: Prof. Jinyan Li (Canada) and Dr Francesco Avella (Italy)
  • Article 14: “Independent Personal Services”: Mr D.P. Sengupta (India)
  • Article 15: “Income from Employment”: Prof. Pasquale Pistone (Netherlands)
  • Article 16: “Directors’ Fees”: Prof. Pasquale Pistone (Netherlands)
  • Article 17: “Entertainers and Sportspersons”: Prof. Jennifer Roeleveld (South Africa) and Dr Karolina Tetłak (Poland)
  • Articles 19(1), 19(3) and 28: “Government Service and Members of Diplomatic Missions and Consular Posts”: Prof. Pasquale Pistone (Netherlands)
  • Article 20: “Students, Teachers and Professors”: Ms Ruxandra Vlasceanu (Netherlands)
  • Article 21: “Other Income”: Prof. Dr Luís Eduardo Schoueri (Brazil)
  • Article 24: “Non-Discrimination”: Dr Niels Bammens (Netherlands) and Prof. Frans Vanistendael (Netherlands)
  • Article 25: “Mutual Agreement Procedure”: Prof. J. Scott Wilkie (United States)
  • Article 26: “Exchange of Information”: Prof. Diane Ring (United States)
  • Articles 3, 29, 30 and 31: “Definitions and Scope in Place and Time”: Ola Ostaszewska
  • Three meta topics on “Interpretation of Tax Treaties”: Prof. John Avery Jones (United Kingdom); “The Interaction of Tax Treaties with International Economic Laws”: Prof. Yariv Brauner (United States) and Prof. Georg Kofler (Austria); and “Time in Tax Treaties”: Dr Joanna Wheeler (Netherlands).

 

  • Unique analytic commentaries on OECD and UN Model provisions, drawing on actual treaty practice
  • Interpretation of OECD, UN, US and other models and actual treaties, TIEAs and MMAA treaties
  • Truly global: information on both OECD and non-OECD member countries of five continents
  • Reliable and authoritative: top experts involved in providing a helicopter view of the subject
  • Objective and collective perspective of a group of authors, editors, reviewers and country experts
  • All in one place: analytic commentaries, models, treaties, case law, primary sources
  • Up-to-date electronic resource linked to related content with user-friendly search functionality
  • Quick Reference Tables – all BEPS implementation measures at a national level.
  • Soon to be added: All model articles provided with comprehensive case law overviews, country tables and bibliographies integrated in the IBFD Tax Research Platform
  • Create and save unique personalized searches and documents under your Favourites
  • BEPS Country Monitor – Search by country (50), organization (OECD) and Action Points, and compare the latest developments and analysis. Links to all relevant information based on your search criteria.
  • Glossary (IBFD International Tax Glossary)

 

Editor-in-Chief

  • Richard Vann, Challis Professor of Law, University of Sydney; Consultant, Greenwoods & Freehills, Australia

Executive Editor

  • Pasquale Pistone, Academic Chairman, IBFD, Netherlands; Jean Monnet ad personam Chair in European Tax Law and Policy, WU University of Economics and Business, Vienna, Austria; Associate Professor of Tax Law, University of Salerno, Italy

Research Editor

Former Research Editor(s) 

Project Coordinator

Editorial Council

  • Brian J. Arnold, Professor Emeritus of Tax Law and Senior Adviser, Canadian Tax Foundation, Canada
  • Hugh Ault, Professor Emeritus at Boston College Law School, Boston, United States
  • John F. Avery Jones, Former Judge of the Upper Tribunal, Tax and Chancery Chamber, United Kingdom
  • Mukesh Butani, Managing Partner, BMR Legal, India
  • Wei Cui, Associate Professor of Law, University of British Columbia, Canada
  • Michael Lang, Head of the Institute for Austrian and International Tax Law; Academic Director, LLM Program and Doctoral Program, WU University of Economics and Business, Vienna, Austria
  • Jinyan Li, Professor of Tax Law, Osgoode Hall Law School, York University, Ontario, Canada
  • Guglielmo Maisto, Founder, Maisto e Associati; Professor of International and Comparative Tax Law, Università Cattolica di Piacenza, Italy
  • Yoshihiro Masui, Professor of Law, University of Tokyo, Japan
  • Detlev J. Piltz, Tax Lawyer; Partner, Flick Gocke Schaumburg; President, German Branch of the International Fiscal Association; Chairman, Fachinstitut der Steuerberater, Germany
  • Jacques Sasseville, Head of the Tax Treaty Unit, OECD Fiscal Affairs Division, Paris, France
  • Luís Eduardo Schoueri, Chairman of Tax Law, University of São Paulo Law School; Partner, Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados; Vice-President, Brazilian Tax Law Institute; Vice-President, Chamber of Commerce, São Paulo, Brazil
  • Kees van Raad, Professor of International Tax Law; Chairman of the International Tax Center, University of Leiden, Leiden; Of Counsel, Loyens & Loeff, Amsterdam, Netherlands
  • Frans Vanistendael, Professor Emeritus, Catholic University of Leuven, Belgium

Chapter Author(s)

  • Brian J. Arnold, Professor Emeritus of Tax Law and Senior Adviser, Canadian Tax Foundation, Canada
  • Stéphane Austry, Partner, CMS Bureau Francis Lefebvre, Neuilly-sur-Seine; Associate Professor, Sorbonne Law School, Paris, France
  • Francesco Avella, Certified Public Accountant and Auditor; Honorary Fellow in Tax Law, Università Cattolica del Sacro Cuore, Sede di Piacenza, Italy
  • John F. Avery Jones, Former Judge of the Upper Tribunal, Tax and Chancery Chamber, United Kingdom
  • Eduardo Baistrocchi, Associate Professor of Law, London School of Economics, London, United Kingdom
  • Niels Bammens, Catholic University of Leuven, Belgium
  • Yariv Brauner, Professor, Research Foundation, University of Florida, Gainesville, FL, United States
  • Patricia A. Brown, Professor, Director Graduate Program in Taxation, School of Law, University of Miami, Florida, United States
  • Wei Cui, Associate Professor of Law, University of British Columbia, Canada
  • Robert Danon, Professor of Swiss and International Tax Law and Director MASIT, University of Lausanne, Lausanne, Switzerland
  • Luc De Broe, Professor and Head of Institute for Tax Law, Catholic University of Leuven, Belgium
  • Ulrika Gustafsson-Myslinksi, Uppsala University, Sweden
  • Daniel Gutmann, Professor, Sorbonne Law School, and Partner, CMS Bureau Francis Lefebvre, Paris, France
  • Peter Harris, University Reader, Churchill College, University of Cambridge, Cambridge, United Kingdom
  • Marjaana Helminen, Professor of International Tax Law, Helsinki University, Helsinki, Finland
  • Michael Lang, Head of the Institute for Austrian and International Tax Law; Academic Director, LLM Program and Doctoral Program, WU University of Economics and Business, Vienna, Austria
  • Jinyan Li, Professor of Tax Law, Osgoode Hall Law School, York University, Ontario, Canada
  • Carl MacArthur, Assistant Professor, Faculty of Law, Western University, London, Ontario, Canada
  • Guglielmo Maisto, Founder, Maisto e Associati; Professor of International and Comparative Tax Law, Università Cattolica di Piacenza, Italy
  • Adolfo Martín Jiménez, Professor of Tax Law, University of Cádiz, Cádiz, Spain
  • Yoshihiro Masui, Professor of Law, University of Tokyo, Japan
  • Belema Obuoforibo, Director, Knowledge Centre, IBFD, Netherlands
  • Ola Ostaszewska, LLM MBA, Head European Knowledge Group, IBFD, Amsterdam, Netherlands
  • Pasquale Pistone, Academic Chairman, IBFD, Netherlands; Jean Monnet ad personam Chair in European Tax Law and Policy, WU University of Economics and Business, Vienna, Austria; Associate Professor of Tax Law, University of Salerno, Italy
  • Diane M. Ring, Professor of Law, Boston College Law School, Boston, Massachusetts, United States
  • Jennifer Roeleveld, Professor and Head Taxation, University of Cape Town, Cape Town, South Africa
  • Jacques Sasseville, Head of the Tax Treaty Unit, OECD Fiscal Affairs Division, Paris, France
  • Luís Eduardo Schoueri, Chairman of Tax Law, University of São Paulo Law School; Partner, Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados; Vice-President, Brazilian Tax Law Institute; Vice-President, Chamber of Commerce, São Paulo, Brazil
  • D.P. Sengupta, Principal Consultant, National Institute of Public Finance and Policy, New Delhi, India
  • Karolina Tetlak, LLM, Assistant Professor, Financial Law Chair, University of Warsaw, Warsaw, Poland
  • Frans Vanistendael, Professor Emeritus, Catholic University of Leuven, Belgium
  • Richard Vann, Challis Professor of Law, University of Sydney; Consultant, Greenwoods & Freehills, Australia
  • Kees van Raad, Professor of International Tax Law; Chairman of the International Tax Center, University of Leiden, Leiden; Of Counsel, Loyens & Loeff, Amsterdam, Netherlands
  • Danil Vinnitsky, Professor, Department Head and Director of the Research Centre for Comparative and International Tax Law, Ural State Academy of Law, Yekaterinburg, Russia
  • Joanna Wheeler, Senior Principal Associate, IBFD, Netherlands
  • Scott Wilkie, Partner, Blake, Cassels & Graydon LLP, Toronto, Ontario, Canada
  • Georg Kofler, Professor of Tax Law at Johannes Kepler University of Linz, Austria

Country Expert(s)

  • Andrey Savitsky, Assistant Professor of Law, Ural State Academy of Law, Yekaterinburg, Russia
  • Bob Michel, Belgium
  • Sven-Eric Bärsch, Tax Advisor, Flick Gocke Schaumburg, Bonn, Germany
  • Xaver Ditz, Tax Advisor, Partner, Flick Gocke Schaumburg, Bonn, Germany
  • Michael Dirkis, Professor of Taxation Law, University of Sydney, Sydney, Australia
  • Paolo Arginelli, Adjunct Professor of Corporate Tax Law and Transnational Law, Università Cattolica del Sacro Cuore, Milano, Italy; Scientific Associate, SUPSI, Lugano, Switzerland
  • Stéphane Austry, Partner, CMS Bureau Francis Lefebvre, Neuilly-sur-Seine; Associate Professor, Sorbonne Law School, Paris, France
  • John F. Avery Jones, Former Judge of the Upper Tribunal, Tax and Chancery Chamber, United Kingdom
  • Eduardo Baistrocchi, Associate Professor of Law, London School of Economics, London, United Kingdom
  • Boyke Baldewsing, Principal Research Associate, IBFD, Amsterdam, Netherlands
  • Mukesh Butani, Managing Partner at BMR Legal, India
  • Wei Cui, Associate Professor of Law, University of British Columbia, Canada
  • Michael Dirkis, Professor of Taxation Law, University of Sydney, Sydney, Australia
  • Charl Du Toit, Partner and Director, PricewaterhouseCoopers, Cape Town, South Africa
  • Jinyan Li, Professor of Tax Law, Osgoode Hall Law School, York University, Ontario, Canada
  • Adolfo Martín Jiménez, Professor of Tax Law, University of Cádiz, Cádiz, Spain
  • Yoshihiro Masui, Professor of Law, University of Tokyo, Japan
  • Victor Matchekhin, Head of Russian Tax Practice, Linklaters LLP; Assistant Professor, Kutafin Moscow State Law University, Moscow, Russia
  • Jérôme Monsenego, Associate Professor of Tax Law, Uppsala University; Tax Advisor at PwC, Uppsala, Sweden
  • René Offermanns, Senior Research Associate, IBFD, Amsterdam, Netherlands
  • Bernard Peeters, Partner, Tiberghien Tax Lawyers, Brussels, Belgium
  • Cesar Alejandro Ruiz Jimenez, Federal Judicial Council, Federal Judicial Branch, Mexico City, Mexico
  • Detlev J. Piltz, Tax Lawyer; Partner, Flick Gocke Schaumburg; President, German Branch of the International Fiscal Association; Chairman, Fachinstitut der Steuerberater, Germany
  • Diane M. Ring, Professor of Law, Boston College Law School, Boston, Massachusetts, United States
  • Luís Eduardo Schoueri, Chair of Tax Law, University of São Paulo Law School; Partner, Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados; Vice-President, Brazilian Tax Law Institute; Vice-President, Chamber of Commerce, São Paulo, Brazil
  • Georges Simon, Avocat à la Cour, and Tax Associate, Loyens & Loeff, Luxembourg
  • Madeleine Simonek, Professor, University of Zurich; Of Counsel, Schellenberg Wittmer Ltd., Zurich, Switzerland
  • How Teck Tan, Associate Professor, Nanyang Technological University, Singapore
  • Richard Vann, Challis Professor of Law, University of Sydney; Consultant, Greenwoods & Freehills, Australia
  • Mario Tenore, Senior Associate, Maisto e Associati, Milan, Italy
  • Jean-Pierre Winandy, Avocat à la Cour, Of Counsel, and Assistant Professor, University of Luxembourg, Luxembourg

 

“The two-tier structure adopted in the development of GTTC allows for an authoritative interpretation of the actual problems, since the authors - all distinguished experts of international tax law - elaborate on issues raised by country experts and derived from tax treaty practice in numerous jurisdictions around the world.”
Pasquale Pistone, Academic Chairman of IBFD
 
“By navigating through the electronic outline, tax professionals will be able to quickly find the relevant text to their issues and be a click away from a wide variety of primary and other secondary sources on tax treaties. It will provide them with a unique resource for considering tax treaties and related issues in international taxation.”

Richard Vann, Editor-in-Chief of GTTC

 
“Having a comprehensive and authoritative reference work written by the world's leading tax treaty specialists will make researching and analyzing tax treaty provisions easier and more efficient.”

Brian J. Arnold, Professor Emeritus of Tax Law and Senior Adviser, Canadian Tax Foundation

 
“This publication will greatly assist courts in reaching reasoned and consistent decisions and will aid both taxpayers and tax authorities in dealing with treaties.”

Hugh J. Ault, Professor Emeritus at Boston College Law School

 
“In providing better and simpler access to information, it will allow tax advisers to deliver more relevant advice.”

Stéphane Austry, Partner at CMS Bureau Francis Lefebvre and Associate Professor at Sorbonne Law School

 

“While interpreting particular provisions of tax treaties, often time it becomes necessary to understand the origin, development and the policy objectives behind such provisions. Equally important is to know how these provisions might have been interpreted in different parts of the world. By making available in a digital format all these important aspects in one place, GTTC will be of immense value to anyone connected with any aspect of international taxation.”

D.P. Sengupta, Principal Consultant at the Indian National Institute of Public Finance and Policy

 

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