The UN Model Convention and its Relevance for the Global Tax Treaty Network
This book analyses the OECD and UN Models by examining the provisions included in the Models, as well as their impact and relevance.
Why this book?
As almost every income tax treaty is based on precedents found in the OECD or UN Model Convention, the practical relevance of the two Models is undeniable. The Models and the Commentaries thereon serve not only as starting points during treaty negotiations but also as significant aids in interpretation in the sense of articles 31 and 32 of the Vienna Convention on the Law of Treaties. Although the UN Model draws strongly from the OECD Model, it pursues a different aim and deviates substantially in certain provisions.
In its 11 chapters, this book provides a detailed analysis of the deviations between the OECD and UN Models. It examines the provisions included in the Models, as well as their impact and relevance.
The book incorporates the perspectives of leading scholars and practitioners in the field of international taxation. Essential insights are provided for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.
The UN Model Convention and Its Relevance for the Global Tax Treaty Network
DOI: https://doi.org/10.59403/a6pc0q
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Chapter 1: The Relevance of the Commentaries on the OECD and UN Models for the Interpretation of the UN Model
DOI: https://doi.org/10.59403/a6pc0q001
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Chapter 2: Business Profits, Permanent Establishments and Associated Enterprises
DOI: https://doi.org/10.59403/a6pc0q002
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Chapter 3: Independent and Dependent Personal Services Benjamin Walker and Alexander Rust
DOI: https://doi.org/10.59403/a6pc0q003
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Chapter 4: International Traffic
DOI: https://doi.org/10.59403/a6pc0q004
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Chapter 5: Passive Income
DOI: https://doi.org/10.59403/a6pc0q005
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Chapter 6: Capital Gains
DOI: https://doi.org/10.59403/a6pc0q006
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Chapter 7: Directors’ Fees and Remuneration of Top-Level Managerial Officials
DOI: https://doi.org/10.59403/a6pc0q007
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Chapter 8: Pensions, Students and Other Income
DOI: https://doi.org/10.59403/a6pc0q008
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Chapter 9: Elimination of Double Taxation
DOI: https://doi.org/10.59403/a6pc0q009
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Chapter 10: Dispute Resolution
DOI: https://doi.org/10.59403/a6pc0q010
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Chapter 11: Exchange of Information and Mutual Assistance in the Collection of Taxes
DOI: https://doi.org/10.59403/a6pc0q011
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Michael Lang, Pasquale Pistone, Alexander Rust, Josef Schuch and Claus Staringer are professors at the Institute for Austrian and International Tax Law of the WU (Vienna University of Economics and Business).
Anna Binder, Peter Bräumann, Eline Huisman, Rita Julien, Matthias Mayer, Nadine Oberbauer, Patrick Orlet, David Orzechowski, Raffaele Petruzzi, Pasquale Pistone, Alexander Rust, Pedro Guilherme Lindenberg Schoueri, Josef Schuch, Selina Siller, Claus Staringer, Michael Tumpel, Laura Turcan, Ben Walker, Viktoria Wöhrer.
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