International Tax Policy and Double Tax Treaties

An Introduction to Principles and Application (Second Revised Edition)

International Tax Policy and Double Tax Treaties (Second Revised Edition)
This book gives the reader an understanding of the concepts that underlie international tax law and double tax treaties.

Why this book?

The world of international tax is constantly changing. Policies change, taxpayers modify their behaviour, laws change, new double tax agreements are concluded, existing ones are amended, and administrative practice is improved. International Tax Policy and Double Tax Treaties gives the reader an understanding of the concepts that underpin the dynamics of international tax law and double tax treaties.

This is an introductory book for an international readership, written primarily as a teaching text for generic international taxation courses. It draws on the tax law, double tax treaties, and experience of different countries to illustrate the application of general principles. The concepts addressed in the book are applicable to the international tax systems of developed, developing and transitional economies.

The book is an excellent learning tool for students and offers a useful refresher on fundamental precepts to experienced practitioners. The numerous case studies provide the reader with the opportunity to apply the principles and examples discussed to factual situations.

This new edition captures recent significant international tax policy and treaty developments, including modifications to the OECD and United Nations model double tax treaties and commentaries concerning permanent establishments and business profits, the taxation of technical services, electronic commerce issues, and international tax avoidance strategies adopted by high-profile multinational enterprises and intergovernmental responses to them.

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Sample excerpt, including table of contents

Author(s)

Dr Kevin Holmes is an international tax adviser to ministries of finance and tax administrations in developing countries. He was formerly a Professor in the School of Accounting and Commercial Law at Victoria University of Wellington, New Zealand, where he specialized in teaching and research in taxation. He was a Principal Research Associate at IBFD in Amsterdam, the Netherlands, head of IBFD’s Government Consultancy Department and a tax partner of an international accountancy firm. Over the past 15 years, Dr Holmes has undertaken a wide variety of tax consulting projects in developing and transitional economies. He is the author of several publications on international taxation.

International Tax Policy and Double Tax Treaties – An Introduction to Principles and Application (Second Revised Edition)
Chapter 1: International Tax Policy
Chapter 2: Double Taxation
Chapter 3: Double Tax Treaties
Chapter 4: Legal Framework of Double Tax Treaties
Chapter 5: Structure of Double Tax Treaties
Chapter 6: Treaty Relief from Juridical Double Taxation
Chapter 7: Personal and Material Scope of Double Tax Treaties
Chapter 8: Residence
Chapter 9: Permanent Establishments
Chapter 10: Business Profits
Chapter 11: Associated Enterprises
Chapter 12: Dividends
Chapter 13: Interest
Chapter 14: Royalties
Chapter 15: Immovable Property
Chapter 16: Capital Gains
Chapter 17: Personal Services
Chapter 18: Other Distributive Articles
Chapter 19: International Tax Avoidance
Chapter 20: Administration of Double Tax Treaties

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