Dispute Resolution under Tax Treaties
As the interrelationship among tax bases continues to parallel the rapid development of the global economy, disputes among governments as to their right to tax international trade and investments under income tax treaties are expected to increase in number and scope.
Winner of the 2006 Mitchell B. Carroll Prize awarded by the International Fiscal Association (IFA).
Why this book?
This study takes an in-depth look at the mechanisms used to resolve such disputes and how they interact with the interests of the various parties involved in the process. The study presents an analysis of the available literature, supplemented by statistical data from North America, Europe and Asia. Analysis of this data leads to interesting insights into the way the dispute resolution process functions when it is applied in different contexts.
The study concludes by suggesting the creation of a new mechanism for the resolution of tax treaty-related disputes, and advocates, in part, the establishment of a new international organization with links to domestic judicial networks. This mechanism is then subjected to the same common framework analysis and checklist used in earlier parts of the study. The analysis suggests how such a mechanism would mitigate some of the most formidable challenges associated with the current dispute resolution procedures.
This book is part of the IBFD Doctoral Series
Before arriving at Harvard University, Dr Zvi D. Altman was an international tax advisor in Israel. He has published numerous articles in professional journals and newspapers, and has lectured extensively on international and domestic tax issues.During his stay at Harvard, Mr Altman held several teaching and fellowship positions. He is currently with the tax group of Sullivan & Cromwell LLP in New York.