We are proud to announce the launch of the second part of the Global Tax Treaty Commentaries (GTTC) collection, focused on Country Policy and Practice.
Since 2014, IBFD’s GTTC publication has become the authoritative source for analysis and commentaries on tax treaty practices across the globe. The first part of the collection, Model Articles and Issues, offers a high-level analysis of each article of the OECD Model and the UN Model over time.
Our latest addition, GTTC Country Policy and Practice, reveals the hidden pattern in the tax treaty policy of a country and the main deviations from the OECD Model, UN Model and/or national tax treaty model in its policy and practice. It explores the possibility of a standard country treaty model and the presence of and reasons for any tax treaty deviations from the OECD and UN Models. You’ll also find reflections on practical issues regarding the interpretation of treaty provisions by courts and tax administrations.
Unlike other products on the market, with little regard for the tax treaty practice from outside Europe and North America, GTTC offers you a truly global perspective, covering both OECD member countries and non-OECD countries from all continents. The article-based commentaries per country are in a standardized format, enabling easy comparison of documents and review of treaty articles and model article commentaries, along with country treaty network analysis, side by side.
Our GTTC second edition is deeply linked to the first collection, GTTC Model Articles and Issues, matching an analysis of each model article in general with the country perspective. Regularly updated, we also ensure that every revision to part one is intertwined with part two. There is an abundance of material on the interpretation and application of treaty variations found in many countries but not reflected in the models, which are now being systematically analysed in a tax treaty commentary. Authors substantiate their statements by references to the OECD Model and the UN Model, official commentaries, treaties, case law, journal articles and other sources, all made accessible by links. Thus, IBFD’s Global Tax Treaty Commentaries can well be regarded as the ultimate encyclopaedia on tax treaty analysis.