Tax Polymath

A Life in International Taxation

Tax Polymath: A Life in International Taxation
This book comprises a selection of papers presented at a conference in honour of John Avery Jones which was held on 22 and 23 April 2010 in London.

Why this book?

This book comprises a selection of papers presented at a conference in honour of John Avery Jones which was held on 22 and 23 April 2010 in London. The conference brought together experts in international and UK domestic taxation from around the world to celebrate Dr. Avery Jones's contribution to the fiscal arena to mark his 70th birthday and forthcoming retirement as Judge of the First and Upper Tier Tax Tribunals.

The participators of the conference were drawn almost exclusively from three groups: the International Tax Group (ITG) of which Dr. Avery Jones was one of the founder members; the Advisory Group on the OECD Model; and UK tax academics. The papers reflect Dr. Avery Jones's many areas of interest, covering both international taxation and various aspects of UK domestic taxation. Many of the papers drew their inspiration from Dr. Avery Jones's academic writings or from his contribution as a tax judge.


Sample excerpt, including table of contents


Brian J. Arnold, Hugh Ault, Philip Baker, Peter H. Blessing, Luc De Broe, Carol A. Dunahoo, Maarten J. Ellis, Michael Lang, Jean Pierre Le Gall, Jinyan Li, Jürgen Lüdicke, Daniel Lüthi, Guglielmo Maisto, Toshio Miyatake, Angelo Nikolakakis, Jacques Sasseville, Henri Torrione, Frans Vanistendael, Kees van Raad, David A. Ward †, Bertil Wiman, Katrien Willoqué.

Tax Polymath: A life in international taxation
The Use of OEEC-OECD Historical Documents in Interpreting Tax Treaties
A Systems-Based Approach to Tax Treaties
Temporal Aspects of Tax Treaties
Double Taxation Conventions and Human Rights
The Concept of Dependence in the Definition of a Permanent Establishment
Contract Conclusion and Agency Permanent Establishments: Here, There, and Everywhere?
The Application of the OECD Permanent Establishment Concept to Electronic Commerce
New Sources of Tax Revenue for Transit Countries: Can a (Rail) Road Qualify as a Permanent Establishment?
Defining the Term “Business” for Purposes of Tax Treaties
Divergence of Third Party Pricing from Arm´s Length Results
Beneficial Ownership in Tax Treaties: Judicial Interpretation and the Case for Clarity
Japan´s Foreign Subsidiaries´ Dividends Exclusion
Exit Taxes on Substantial Shareholdings and Pension Claims: The Dutch Supreme Court´s Interpretation of Arts. 13, 15 and 18 of the OECD Model
Tax Treaty Override – Swedish Developments
Does Art. 20 of the OECD Model Convention Really Fit into Tax Treaties?
Exemption and Tax Credit in German Tax Treaties – Policy and Reality
Recent Treaty Developments in the Arbitration of International Tax Disputes
The Exercise of Legislative Taxing Powers in Occupied Territories
Tax Law: Rules or Principles – Madness or Genius? Mind the Gaps!
Can Member States Survive EU Taxation? Can the European Union Survive National Taxation?
Conference papers published in the special issue of the British Tax Review in honour of John Avery Jones (issue No. 6 of 2010)
Joint articles (lead author)
Joint articles (contributing author)
Contributions to books
Finance Bill or Act notes
Case notes