Taxes Covered under Article 2 of the OECD Model

The Scope of Tax Treaties in a Dynamic Global Environment of Newly Created Taxes

This book explores the relationship between article 2 of the OECD Model Conventions 1982 and 2017.

Why this book?

The material scope of double taxation conventions is the starting point for any application of the agreement, since the understanding of the relevant terms in article 2 of the OECD Model Convention determines whether a treaty is applicable. However, the definition of the material scope of both the OECD Model Convention on Income and on Capital (2017) and the OECD Model Convention on Inheritances, Estates and Gifts (1982) has so far received only little attention in the academic literature.

This book aims to explore the relationship between the OECD Model Conventions 1982 and 2017. Therefore, it analyses crucial areas concerning article 2 of the OECD Model Conventions 1982 and 2017. The topics include:

  • The notion of “tax” according to article 2 of the OECD Model Conventions 1982 and 2017
  • The list of taxes according to article 2(3) of the OECD Model Conventions 1982 and 2017
  • Identical or substantially similar taxes according to article 2(4) of the OECD Model Conventions 1982 and 2017
  • Digital taxes and article 2 of the OECD Model Conventions 1982 and 2017
  • Double protection under article 2 of the OECD Model Conventions 1982 and 2017?
  • Tax treaty application beyond the scope of article 2 of the OECD Model Conventions 1982 and 2017 (non-discrimination, mutual agreement and mutual assistance)

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This book is part of the WU Institute for Austrian and International Tax Law - Tax Law and Policy Series

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Editor(s)

Georg Kofler, Michael Lang, Pasquale Pistone, Alexander Rust, Josef Schuch, Karoline Spies and Claus Staringer are professors at WU Vienna University of Economics and Business, Institute for Austrian and International Tax Law.

Contributor(s)

Gabriela Capristano Cardoso, Martha Caziero, Stefanie Chroustovsky, Georg Kofler, Ashrita Prasad Kotha, Martin Klokar, Christian Knotzer, Shimeng Lan, Michael Lang, Xiangdan Luo, Markus Mittendorfer, Cristóbal Pérez Jarpa, Pasquale Pistone, Mario Riedl, Alexander Rust, Josef Schuch, Karoline Spies, Claus Staringer, Andreas Ullmann.