Global Tax Treaty Commentaries (GTTC)
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.
Global Tax Treaty Commentaries (GTTC)
The IBFD Global Tax Treaty Commentaries (GTTC) is the authoritative source for analysis and interpretation of tax treaty practices across the globe. This peer-reviewed, cutting-edge publication is authored by world-class academics and tax practitioners.
The GTTC Model articles and Issues collection provides high-level analysis of and commentaries with respect to each article in the OECD Model and the UN Model, along with a series of chapters on meta-topics. The GTTC Country Policy and Practice guides offer a comprehensive analysis of the treaty practice of many countries worldwide.
GTTC Country Policy and Practice identifies patterns in the tax treaties of a country and the main deviations from the OECD Model, UN Model and/or national tax treaty model in its policy and practice. The possible existence of a standard country treaty model and the presence of and reasons for any tax treaty deviations from the OECD and UN Models are assessed. This could include revealing different policies for treaties entered into with developing and developed countries. Furthermore, the publication reflects practical issues regarding the interpretation of treaty provisions by courts and tax administrations. GTTC Country Policy and Practice also indicates whether case law or tax rulings on the interpretation of treaties of a jurisdiction refer to recommendations from international organizations such as the OECD and UN or the Vienna Convention on the Law of Treaties.
The GTTC collection set incorporates the alternative treaty instruments developed in recent years in relation to tax administrative cooperation. These include tax information exchange agreements (TIEAs), the multilateral mutual administrative assistance (MMAA) treaty and ,of course, the Multilateral Instrument and how it has affected domestic treaty policy and tax treaties already in force.
The two collections, focusing on model analysis and country practice respectively, are intertwined. They follow an organic structure that will do justice to the interaction of the articles of the OECD Model and the UN Model in theory and practice in various countries. The publications are regularly updated, with all revisions remaining connected with each other. An abundance of material on the interpretation and application of treaty variations found in many countries but not reflected in the models is systematically analysed. Authors substantiate their statements by reference to the OECD Model and the UN Model, official commentaries, treaties, case law, journal articles and other sources, all accessible via hyperlinks.
GTTC Model Articles and Issues:
As theory and practice do not always coincide, this publication covers commentary not only on the model conventions but also on the most important variations, as well as diverging national tax treaty policies. The commentaries are based on the perspectives of internationally renowned experts on each article. The collection gives a complete picture of the realities of everyday international tax treaty practice and reflects the impact of recent instruments such as the MLI, tax information exchange agreements (TIEAs) and the MMAA treaty.
GTTC Model Articles and Issues has been completed and consists of 30 chapters, each dedicated to one of the articles of the OECD and UN Model provisions, along with six chapters on important meta-topics relating to specific issues: “Treaty Interpretation”, “Interaction of Tax Treaties with International Economic Laws”, “Time in Tax Treaties”, “Application of Tax Treaties to Fiscally Transparent Entities”, “Qualification Conflicts”, “Beneficial Ownership” and “Triangular Cases”. By weaving all these aspects together, in combination with seamless links to other content on the IBFD Tax Research Platform, IBFD offers tax professionals – from the advisory and corporate sectors to government and the judiciary, along with the academic arena – a rich tapestry of information unmatched by any existing product.
GTTC Country Policy and Practice:
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 now covers 20 countries, and more are to follow from all continents. GTTC Country Policy and Practice is deeply linked to GTTC Model Articles and Issues, matching an analysis of each model article in general with the country perspective. The chapters will be highly standardized, enabling search and comparison per article per country. The publication is suitable for tax professionals from the corporate and advisory sectors, as well as for governments, universities, and the judiciary.
The scholars, practitioners and tax officials authoring the publication establish whether a jurisdiction uses its own (official or non-official) tax treaty model or follows a documented tax treaty policy. These top-notch experts determine the possible existence of a standard country treaty approach per country. They assess the presence of and the reasons for any tax treaty deviations from the OECD and UN Models and determine whether there are different policies for treaties entered into with developing and developed countries. The collection allows the user to get a comprehensive view per treaty article per country. It helps to elucidate not only the different articles of the model conventions and the diverging national treaty policies but also how each rule has been incorporated in a country’s treaty network and policy. It thereby takes the same approach as used in the GTTC Model Articles and Issues publication.
The collection also addresses whether case law or tax rulings on the interpretation of treaties of a jurisdiction refer to recommendations from international organizations such as the OECD and UN or the Vienna Convention on the Law of Treaties. GTTC Country Policy and Practice will be regularly updated to track developments and assess the effect of new instruments like the MLI on domestic treaty policy and the tax treaties already in force.
- Unique analytic commentaries on OECD Model and UN Model provisions and the treaty networks of countries, drawing on actual treaty practice
- Interpretation of the OECD, UN and US Models, other models and actual treaties, along with TIEAs and MMAA treaties
- Truly global: Information includes both OECD and non-OECD member countries of five continents
- Reliable and authoritative: Top experts involved, providing a helicopter view of the subject
- Objective and collective perspective of a group of authors, editors and reviewers
- All interlinked on the IBFD Tax Research Platform: Analytic commentaries, models, treaties, case law, primary sources, country guides
João Félix Pinto Nogueira
Cristian San Felipe Maestre
- Jennifer Roeleveld, Professor of Tax Law, University of Cape Town, Cape Town, South Africa
- Diane M. Ring, Professor of Law, Boston College Law School, Boston, United States
- Luis 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
- Jacques Sasseville, Consultant for the Financing for Sustainable Development Office of the United Nations (DESA)
- Li Na, Professor of International Tax Law, East China University of Political Science and Law, Shanghai, China
Richard Vann, Challis Professor of Law, University of Sydney, and Consultant, Greenwoods & Freehills, Australia
- 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
- 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
GTTC Model Articles and Issues
“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, Founding 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
GTTC Country Policy and Practice
“This publication contributes important voices to the discussion and understanding of global tax treaty practice. Being a vital tool for all tax practitioners, it serves as the ideal platform, with a blend of theory and practice in the field of international taxation.”
Mukesh Butani, Managing Partner, BMR Legal Advocates
“The guidance from leading experts on articles and treaty approaches in the GTTC, combined with the mapping of similarities and differences in treaty practice in the detailed country chapters, makes this an essential reference for global tax treaty law and practice today.”
Miranda Stewart, Professor, Melbourne Law School