Judicial interpretation of tax treaties: the use of the OECD Commentary

Resource Information

The work Judicial interpretation of tax treaties: the use of the OECD Commentary represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Books.

Label

Judicial interpretation of tax treaties: the use of the OECD Commentary

Creator

• Garbarino, C

Subject

• OECD
• OECD Model Commentaries
• PE
• associated enterprises
• business profits
• capital gains
• case law
• debt
• dispute resolution
• double taxation
• employment income
• MAP
• equity capital
• exchange of information
• immovable property
• investment
• non-discrimination
• pension
• residence
• royalties
• sportsmen
• tax treaty
• entertainer

Language

eng

Summary

This book provides an analytical guide to the interpretation of tax treaties at a national level. It focuses on how domestic courts interpret and apply the OECD Commentary to OECD Model Tax Convention on Income and on Capital. The book gives a systematic presentation of the main interpretive proposals put forward by the OECD Commentary, and analyses selected cases decided in domestic tax systems in order to assess whether and how such solutions are adopted through national judicial process, and indeed which of these are of most practical value. The book provides a comprehensive framework of tax treaty law and provides guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation

Geographic coverage

• European Union
• International

Index

no index present

Language note

English

Literary form

non fiction

Series statement

Elgar Tax Law and Practice