The UN Model Convention and its Relevance for the Global Tax Treaty Network

Type Book

Series

WU - Tax Law and Policy Series

Editor(s)

Michael Lang et al.

Date of publication

October 2017

DOI https://doi.org/10.59403/a6pc0q

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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.

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Sample excerpt, including table of contents

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)

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).

Contributor(s)

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.
















The UN Model Convention and Its Relevance for the Global Tax Treaty Network: https://doi.org/10.59403/a6pc0q
Chapter 1: The Relevance of the Commentaries on the OECD and UN Models for the Interpretation of the UN Model: https://doi.org/10.59403/a6pc0q001
Chapter 2: Business Profits, Permanent Establishments and Associated Enterprises: https://doi.org/10.59403/a6pc0q002
Chapter 3: Independent and Dependent Personal Services Benjamin Walker and Alexander Rust: https://doi.org/10.59403/a6pc0q003
Chapter 4: International Traffic: https://doi.org/10.59403/a6pc0q004
Chapter 5: Passive Income: https://doi.org/10.59403/a6pc0q005
Chapter 6: Capital Gains: https://doi.org/10.59403/a6pc0q006
Chapter 7: Directors’ Fees and Remuneration of Top-Level Managerial Officials: https://doi.org/10.59403/a6pc0q007
Chapter 8: Pensions, Students and Other Income: https://doi.org/10.59403/a6pc0q008
Chapter 9: Elimination of Double Taxation: https://doi.org/10.59403/a6pc0q009
Chapter 10: Dispute Resolution: https://doi.org/10.59403/a6pc0q010
Chapter 11: Exchange of Information and Mutual Assistance in the Collection of Taxes: https://doi.org/10.59403/a6pc0q011