"Taxes covered" : a study of Article 2 of the OECD Model Tax Conventions

Resource Information

The work "Taxes covered" : a study of Article 2 of the OECD Model Tax Conventions 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

"Taxes covered" : a study of Article 2 of the OECD Model Tax Conventions

Contributor

• Brandstetter, P

Subject

• OECD
• OECD Model
• case law
• inheritance tax treaty
• tax treaty
• treaty interpretation

Language

eng

Summary

The substantive scope of a tax treaty determines the extent of protection it can provide against international double taxation. Countries worldwide have adopted the text of Art. 2 ("Taxes covered") of the OECD Model Tax Conventions in their bilateral tax treaties. However, the structure and wording of Art. 2, which have remained virtually unchanged since the beginnings of tax treaty law in the 1920s, create interpretive issues and uncertainties in practical treaty application. This book not only provides an analysis of recent case law and academic literature, but also sheds light on the background to the standard formulations so widely used in the provision on the substantive scope of today's tax treaties. The source documents used have rarely found their way into publications before: historical OEEC and OECD Reports and Minutes, originally largely classified as "restricted" and thus inaccessible to the public for decades, provide an insight into the drafting process of Art. 2 and the discussions of Delegates from various nations on practical implications for treaty application. The book aims to contribute to the understanding of the "taxes covered" and to guide subsequent research and heighten awareness of problems in the interpretation and application of the provision on substantive scope in tax treaties

Geographic coverage

International

Index

no index present

Language note

English

Literary form

non fiction