The Resource Double taxation conventions

Double taxation conventions

Label
Double taxation conventions
Title
Double taxation conventions
Creator
Subject
Language
eng
Summary
This essay deals with: The history of tax treaties and model conventions; Purpose of double taxation conventions; Relationship of tax treaties and domestic law; Tax treaty interpretation: The Vienna Convention, Reference to OECD Commentaries, the interpretation rule of art. 3(2) of the OECD Model, conflicts of qualification; Basic contents of the Model tax treaty: coverage and scope, income from immovable property, business income, dividends, interest and royalties, employment and pension income, capital gains and the "other income" article, non-discrimination, mutual agreement procedure, exchange of information and assistance in the collection of taxes; Treaty shopping
Citation source
Bound in: International tax law. - Alphen aan den Rijn : Kluwer Law International, 2006 ; p. 149-181
http://library.link/vocab/creatorName
Uckmar, V
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • tax treaty
  • treaty interpretation
  • OECD Model
  • treaty shopping
  • domestic tax law
  • Vienna Convention on the Law of Treaties
  • qualification conflict
  • immovable property
  • dividend
  • interest
  • royalties
  • employment income
  • pension
  • capital gains tax
  • other income
  • non-discrimination
  • MAP
  • exchange of information
Label
Double taxation conventions
Publication

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