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The principal purpose of this study is to analyse and discuss the rules and principles of international law relevant to the interpretation of treaties in general, and their application to tax treaties in particular. The rules of international law enshrined in Articles 31, 32 and 33 of the Vienna Convention on the Law of Treaties are discussed in detail. Where appropriate, reference is made to the jurisprudence of the International Court of Justice, and to the law and procedure of other international courts and tribunals. Since tax treaties are not only a source of legal rights and obligations for the contracting States, but can also be invoked by the taxpayers of those States, this book considers the extent to which the relevant rules and principles of international law are binding on domestic courts and taxpayers. The effect of international law in a State's national legal order is largely dependent on its relevant rules of constitutional law, which vary from country to country. In order to address this issue, the book draws upon the example of the Netherlands and provides a number of leading cases decided by the Dutch Supreme Court (Hoge Raad).
International taxation is a vital issue for a growing number of business and individuals across the world. The need to understand how the international system of taxation works is therefore a subject of importance to many people. The International Taxation System provides this understanding by bringing together experts from the most important fields in the subject who have each authored chapters especially for this book. They each provide brief, structured and easy to understand explanations of the key concepts edited together into one volume to provide a unique, very readable, guide to the field. While this text is aimed at masters or advanced undergraduate level students, it will also be of interest to those requiring a professional understanding of the topic. Each chapter introduces a different aspect of the international taxation system, explains the important issues to be understood in each case and provides suggestions for discussion and further reading.
Bilateral tax treaties are often, to a greater or lesser extent, based on the OECD Model Convention. Among the distributive rules with respect to taxation of income which are laid down in Chapter III of that model, Article 21 assigns the tax jurisdiction in respect of "other income" - understood to mean items of income which are not dealt with in other provisions of the tax treaty - to the residence state in accordance with the main rule underlying the OECD Model, thus ensuring that no income falls outside the scope of the treaty. This study provides a comprehensive analysis of Article 21 of the OECD Model. In extensive detail, and with reference to case law from a number of jurisdictions and to statements of various authorities and official documents, the author shows how Article 21 operates in relation to the other distributive rules of the OECD Model and bilateral tax treaties based thereon. The analysis considers such items of income as the following in relation to Article 21: - income from immovable property; - business profits; - profits from shipping, inland waterways transport, and air transport; - dividends, interest, and royalties; - capital gains; and - income from employment. In addition, the author examines the significance of the OECD Commentaries for the interpretation of tax treaties, the "other income" article in other model conventions, and notable deviations from Article 21 among bilateral tax treaties. An appendix offers well-grounded recommendations on how to potentially amend the wording of Article 21 and the related commentary and how the application of the article can be improved. Although underexposed in the tax law literature heretofore, the "other income" article raises important international taxation issues that remain problematic or unresolved. Tax lawyers, government officials, and other interested professionals will find here a penetrating analysis that goes a long way towards clarifying the characterisation of income that resists the standard categories defined in tax treaties.
This title is one of six releases from the LexisNexis Graduate Tax Series. United States International Taxation embodies the dual goals established for the LexisNexis Graduate Tax Series: to provide graduate tax students with a solid foundation in the applicable rules and to enhance their skills in reading and applying complex statutes and regulations. To this end, the text relies very little on the often-times laborious analysis of cases and other sources that are secondary to the Code and the regulations. Instead, each chapter provides an overview of the substantive content, with emphasis on important issues that are not apparent from the language of the Code and regulations. This book contains teaching materials for law school courses in the United States federal income taxation of persons engaged in cross-border activities and transactions. It contains 21 separate Units that address fundamental concepts of residency and source, the taxation of United States persons (citizens, residents, and domestic corporations) on their activities within the United States, and the safeguard rules in place to curtail potentially abusive tax avoidance in the international context.
Differing provisions in bilateral tax treaties lead to undesired consequences. Tax administrations expend considerable energy combating tax structures devised by taxpayers and their advisers who attempt to use these differences to their advantage. This battle uselessly engages the resources of both enterprises and tax authorities. A model multilateral tax treaty could provide the solution to this problem. The advantages and disadvantages of multilateral tax treaties have been debated for many years. While some multilateral tax treaties have been concluded at regional levels, the concept has yet to gain wide acceptance. Multilateral Tax Treaties results from a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project sought to produce a draft multilateral tax treaty modeled on the OECD Model Income Tax Convention while examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a thorough analysis of the arguments for and against the conclusion of a multilateral tax treaty and of the various European law issues that arise in this context. Multilateral Tax Treaties provides incisive and thought-provoking reading for the international tax specialist and generates further discussion on this important topic.
This helpful study aid updates international aspects of tax systems originating in national environments. It focuses on U.S. taxation as applied to economic activity with an international element. The Third Edition is divided into four sections: basic elements of international taxation, inbound U.S. taxation, outbound U.S. taxation, and income tax treaties. This new offering is from the Concepts and Insights Series and is designed as recommended reading to complement casebook instruction.

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