Tax Treaties and Procedural Law
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Written by experts in the field, this book provides an in-depth analysis of several crucial areas concerning the procedural aspects of tax treaty law.
Why this book?
The application of tax treaties relies, to a large extent, on procedural law. While procedural provisions in tax treaties exist, the implementation of tax treaty law generally lies within the procedural autonomy of the contracting states. Domestic procedural law, therefore, is imperative for the implementation of tax treaty benefits.
This book analyses several crucial areas concerning the procedural aspects of tax treaty law. The topics covered include:
- domestic procedural law and EU law;
- domestic procedural law and tax treaty law;
- domestic procedural law and non-discrimination;
- the implementation of the methods to avoid double taxation in domestic law;
- the implementation of mutual agreements in domestic law;
- the implementation of arbitration awards in domestic law;
- mutual assistance procedures and domestic law;
- the role of the competent authorities under the new tiebreaker rule (article 4(3) of the OECD Model Tax Convention);
- the "mode of application" for withholding tax limitations (articles 10(2) and 11(2) of the OECD Model Tax Convention);
- procedural aspects of the grace clause for potentially abusive triangular structures (article 29(8)(c) of the OECD Model Tax Convention); and
- procedural aspects of the principal purpose test (article 29(9) of the OECD Model Tax Convention).
Tax Treaties and Procedural Law
DOI: https://doi.org/10.59403/110m7e8
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Chapter 1: Domestic Procedural Law and EU Law
DOI: https://doi.org/10.59403/110m7e8001
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Chapter 2: Domestic Procedural Law and Tax Treaty Law
DOI: https://doi.org/10.59403/110m7e8002
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Chapter 3: Domestic Procedural Rules and Non-Discrimination
DOI: https://doi.org/10.59403/110m7e8003
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Chapter 4: The Role of Competent Authorities under Article 4(3) of the OECD Model Tax Convention
DOI: https://doi.org/10.59403/110m7e8004
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Chapter 5: Articles 10(2) and 11(2) of the OECD Model Tax Convention: Direct Applicability, Refund and the Competence of Competent Authorities to Settle the Mode of Application
DOI: https://doi.org/10.59403/110m7e8005
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Chapter 6: The Methods to Avoid Double Taxation and Their Implementation in Domestic Law
DOI: https://doi.org/10.59403/110m7e8006
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Chapter 7: Mutual Agreement Procedures and the Implementation of Mutual Agreements in Domestic Law
DOI: https://doi.org/10.59403/110m7e8007
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Chapter 8: Arbitration Procedure and the Implementation of Arbitral Awards in Domestic Law
DOI: https://doi.org/10.59403/110m7e8008
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Chapter 9: Mutual Assistance Procedure and Domestic Law
DOI: https://doi.org/10.59403/110m7e8009
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Chapter 10: The Grace Clause of Article 29(8)(c) of the OECD Model Tax Convention and Its Procedural Aspects
DOI: https://doi.org/10.59403/110m7e8010
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Chapter 11: The Procedural Aspects of the Principal Purpose Test (Article 29(9) of the OECD Model Tax Convention)
DOI: https://doi.org/10.59403/110m7e8011
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Georg Kofler, Michael Lang, Pasquale Pistone, Alexander Rust, Josef Schuch, Karoline Spies and Claus Staringer are professors at the Institute for Austrian and International Tax Law, WU (Vienna University of Economics and Business).
Christina Dimitropoulou, Karol Dziwiński, Florian Fiala, Heinz Jirousek, Michael Lang, Katharina Moldaschl, Marta Olowska, Angelina Papulova, Pasquale Pistone, Christina Pollak, Ioana-Felicia Rosca, Alexander Rust, Josef Schuch, Claus Staringer, Annika Streicher, Andreas Ullmann and Jean-Philippe Van West.
