The Resource Home sweet home : tax treaty interpretation and the problem with language under consideration of the permanent home tie-breaker

Home sweet home : tax treaty interpretation and the problem with language under consideration of the permanent home tie-breaker

Label
Home sweet home : tax treaty interpretation and the problem with language under consideration of the permanent home tie-breaker
Title
Home sweet home : tax treaty interpretation and the problem with language under consideration of the permanent home tie-breaker
Creator
Subject
Language
eng
Summary
This article discusses how language idiosyncrasies affect the interpretation and application of tax treaties in practice, causing interpretative schisms in the international arena. To illustrate, it analyses, in detail, the interpretation of the permanent home tie-breaker by the German Federal Fiscal Court, German commentators, and the German tax administration. The example shows that reliance on the harmonising powers of the OECD Model and Commentary alone is no substitute for a comparison with the other authentic language texts or for having additional recourse to the prevailing text when such exists
Citation source
In: British tax review. - London. - (2019), no. 2 ; p. 205-231
http://library.link/vocab/creatorName
Resch, R.X
Geographic coverage
  • European Union
  • Europe
  • International
Language note
English
http://library.link/vocab/subjectName
  • OECD Model
  • OECD Model Commentaries
  • tax treaty
  • treaty interpretation
  • permanent home available
  • tie-breaker rule
  • case law
  • PE
Label
Home sweet home : tax treaty interpretation and the problem with language under consideration of the permanent home tie-breaker
Instantiates
Publication
Label
Home sweet home : tax treaty interpretation and the problem with language under consideration of the permanent home tie-breaker
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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