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The Un Model Convention And Its Relevance For The Global Tax Treaty Network
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Book Synopsis The UN Model Convention and Its Relevance for the Global Tax Treaty Network by : Michael Lang
Download or read book The UN Model Convention and Its Relevance for the Global Tax Treaty Network written by Michael Lang and published by . This book was released on 2017 with total page 352 pages. Available in PDF, EPUB and Kindle. Book excerpt: As almost every income tax treaty is based on precedents found in the OECD or UN Model Convention, the practical relevance of the two Models is undeniable. The Models and the Commentaries thereon serve not only as starting points during treaty negotiations but also as significant aids in interpretation in the sense of articles 31 and 32 of the Vienna Convention on the Law of Treaties. Although the UN Model draws strongly from the OECD Model, it pursues a different aim and deviates substantially in certain provisions.0In its 11 chapters, this book provides a detailed analysis of the deviations between the OECD and UN Models. It examines the provisions included in the Models, as well as their impact and relevance.0The book incorporates the perspectives of leading scholars and practitioners in the field of international taxation.
Book Synopsis Special Features of the UN Model Convention by : Anna Binder
Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 664 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.he OECD's BEPS project on the UN Model.
Book Synopsis A Multilateral Convention for Tax by : Sergio André Rocha
Download or read book A Multilateral Convention for Tax written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2021-11-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.
Book Synopsis Article 12B UN Model Convention 2021 by : Christian Knotzer
Download or read book Article 12B UN Model Convention 2021 written by Christian Knotzer and published by Kluwer Law International B.V.. This book was released on 2024-07-15 with total page 551 pages. Available in PDF, EPUB and Kindle. Book excerpt: This groundbreaking book – a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy – provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for ‘Income from Automated Digital Services’. In extensive detail, the author thoroughly examines the article’s underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author’s analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book’s clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.
Book Synopsis The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties by : Michael Lang
Download or read book The Impact of the OECD and UN Model Conventions on Bilateral Tax Treaties written by Michael Lang and published by Cambridge University Press. This book was released on 2012-05-17 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides an analysis of bilateral tax treaties concluded by thirty-seven jurisdictions from five continents and empirically ascertains the impact of the UN and OECD Model Tax Conventions on bilateral tax treaties. It therefore fills a major gap in the international tax literature, which has so far either studied the sole Model Tax Conventions or focused on bilateral treaties in the context of the tax treaty policy of single countries, and sets the pace for a new methodology in the analysis and interpretation of tax treaties. A general report outlines the key points of the analysis, highlights current trends and predicts future developments of multilateralism and global tax law. This is an essential resource for academics, tax authorities and international tax practitioners who find textbooks based on Model Tax Conventions insufficient.
Book Synopsis Article 12B UN Model Convention 2021 by : Christian Knotzer
Download or read book Article 12B UN Model Convention 2021 written by Christian Knotzer and published by . This book was released on 2024-07-15 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This groundbreaking book - a major contribution addressing the imperative to find a solution to what has been labelled as the Tax Challenges Arising from the Digitalization of the Economy - provides the first comprehensive analysis of Article 12B of the UN Model Double Taxation Convention 2021, a model distributive rule for 'Income from Automated Digital Services'. In extensive detail, the author thoroughly examines the article's underlying principles, its individual provisions, the tax policy context that surrounds it, how it might be applied, and what its strengths and weaknesses are. The author's analysis (which includes a paragraph-by-paragraph discussion of the article and examines its Commentary in extensive detail) covers all aspects of the article and its significance, including the following: how to reconcile the approach taken by Article 12B UN Model Convention with general principles underlying the coordination of taxing claims; legal and tax policy relation to other provisions of the UN Model Convention and to the OECD/Inclusive Framework Pillar One/Amount A; influence of developing countries in forums of international tax coordination; the value of country positions and minority views in Model Conventions; categories of digital services; the novel option for annual net taxation in Article 12B(3) UN Model Convention; and the proposal for a UN fast-track instrument. It is not surprising that the ubiquitous digitalization of the economy has led to a widespread sense of unease in the international tax community. Practitioners and policymakers who face this issue in their day-to-day work will greatly appreciate this book's clear explanation of how Article 12B UN Model Convention works and benefit from its consideration of how it is likely to be implemented in the international double taxation treaty network.
Book Synopsis United Nations Model Convention for Tax Treaties Between Developed and Developing Countries by : Stanley S. Surrey
Download or read book United Nations Model Convention for Tax Treaties Between Developed and Developing Countries written by Stanley S. Surrey and published by . This book was released on 1980 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 1967, the United Nations Group of Experts on Tax Treaties Between Developed and Developing Countries was established to facilitate the conclusion of tax treaties between developing and developes countries. This task was to be accomplished through the formation of guidelines for these treaties and recommendations for their implementation. This monograph describes the the work of this UN Group.
Book Synopsis Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries by : United Nations Publications
Download or read book Papers on Selected Topics in Negotiation of Tax Treaties for Developing Countries written by United Nations Publications and published by . This book was released on 2014 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: Double tax treaties play a key role in the context of international taxation, by reducing or eliminating double taxation over cross-border income, thus encouraging international investment and global economic growth, and by enhancing cooperation among tax administrations, especially in tackling international tax evasion and avoidance. This publication, which is designed especially for developing countries, aims at providing practical guidance to effectively negotiate double tax treaties and, in particular, those drawing upon the United Nations Model Double Taxation Convention between Developed and Developing Countries. It is the companion of the already released United Nations Handbook on Selected Issues in Administration of Double Tax Treaties for Developing Countries, which provides practical guidance on how to apply concluded tax treaties. Primary audiences are officials of ministries of finance and national tax authorities and other tax professionals dealing with international taxation matters, the general public, media and universities.
Book Synopsis United Nations Model Double Taxation Convention Between Developed and Developing Countries by :
Download or read book United Nations Model Double Taxation Convention Between Developed and Developing Countries written by and published by . This book was released on 2012 with total page 504 pages. Available in PDF, EPUB and Kindle. Book excerpt: Text of, and commentary on, the U.N. Model Double Taxation Convention.
Author :United Nations Conference on Trade and Development. Programme on Transnational Corporations Publisher :New York : United Nations ISBN 13 : Total Pages :744 pages Book Rating :4.3/5 (91 download)
Book Synopsis Sociétés Transnationales by : United Nations Conference on Trade and Development. Programme on Transnational Corporations
Download or read book Sociétés Transnationales written by United Nations Conference on Trade and Development. Programme on Transnational Corporations and published by New York : United Nations. This book was released on 1993 with total page 744 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Model Tax Convention on Income and on Capital: Condensed Version 2014 by : OECD
Download or read book Model Tax Convention on Income and on Capital: Condensed Version 2014 written by OECD and published by OECD Publishing. This book was released on 2014-08-20 with total page 496 pages. Available in PDF, EPUB and Kindle. Book excerpt: The OECD Model Tax Convention provides the basis for the negotiation and interpretation of more than 3000 tax treaties that make up a network that co-ordinate the income and corporate tax systems of most countries with the objective of removing tax barriers to cross-border trade and investment.
Author :United Nations. Department of Economic and Social Affairs Publisher :United Nations Publications ISBN 13 : Total Pages :418 pages Book Rating :4.3/5 (91 download)
Book Synopsis United Nations Model Double Taxation Convention Between Developed and Developing Countries by : United Nations. Department of Economic and Social Affairs
Download or read book United Nations Model Double Taxation Convention Between Developed and Developing Countries written by United Nations. Department of Economic and Social Affairs and published by United Nations Publications. This book was released on 2001 with total page 418 pages. Available in PDF, EPUB and Kindle. Book excerpt: The growth of investment flows from developed to developing countries depends on the international investment climate. An important component of this climate is the prevention of double taxation, i.e. the imposition of similar taxes in two or more states on the same taxpayer. Bilateral tax treaties have eased this problem and in 1980 the United Nations published a model double taxation convention between developed and developing countries. This has now been revised to take account of the changes in the globalisation of trade and finance since 1980. Although it is based on the OECD Model Convention, there are differences as it gives more weight to the source principle as opposed to the residence principle.
Book Synopsis Looking Ahead:Inter-National Law in 21st by : D.M. Broekhuijsen
Download or read book Looking Ahead:Inter-National Law in 21st written by D.M. Broekhuijsen and published by Springer. This book was released on 2002-03-21 with total page 298 pages. Available in PDF, EPUB and Kindle. Book excerpt: Many states have set out to develop a multilateral tax instrument with the purpose of amending bilateral treaties in a quick and comprehensive fashion. The recent adoption by as many as a hundred jurisdictions of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the OECD Multilateral Instrument) is the most prominent step in this direction. This book provides not only a detailed analysis of the OECD Multilateral Instrument but also discusses in depth the far-reaching implications of the international tax reform currently under way. The author shows how the BEPS Project has merely unveiled the problems related to bilateral tax relationships and articulates initiatives to ensure the sustainability of a multilateral consensus. Drawing on the fields of international law, international relations, and political science, he develops a design strategy, complete with draft clauses, that fundamentally transforms the way states cooperate in the field of international tax, effectively addressing such problems as the following: – the need for collective action; – the problem structure of multilateral tax cooperation; – the relevance of the OECD Model Tax Convention and Commentaries thereon; – the place, position and operation of the OECD Multilateral Instrument; – non-OECD member countries; and – treaty shopping. The principled and pragmatic structural solution presented would allow policymakers to continuously adapt and respond to the rapidly evolving nature of the global economy. The author’s original research and his recommendations for future development of the topic offer deeply informed guidance to policymakers, practitioners and other tax professionals, and academics.
Book Synopsis Interpretation and Application of Tax Treaties in North America by : Juan Angel Becerra
Download or read book Interpretation and Application of Tax Treaties in North America written by Juan Angel Becerra and published by IBFD. This book was released on 2007 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book presents an overview of the materials, court cases and mutual agreement procedures implemented in Canada, USA and Mexcio. In addition, it provides a background to the development of tax treaty law and the information necessary to interpret a tax treaty based upon the principles codified in the Vienna Convention of the Law of Treaties. Contents: the background of the early model tax conventions; the development of tax treaty law; the specific materials from Canada, the United States and Mexico; proposal for a trilateral tax treaty for North America to provide full relief from the harmful barriers against free movement of capital and services.
Book Synopsis Model Tax Convention on Income and on Capital by :
Download or read book Model Tax Convention on Income and on Capital written by and published by . This book was released on 2008 with total page 428 pages. Available in PDF, EPUB and Kindle. Book excerpt: This publication is the condensed version of the OECD Model Tax Convention on Income and Capital. This shorter version contains the full text of the Model Tax Convention, but without the historical notes, the detailed list of tax treaties between OECD member countries and the background reports that are included in the full-length loose-leaf and electronic versions. The Model Tax Convention, and the worldwide network of treaties based on it, provide clear consensual rules for taxing income and capital across countries, while avoiding having income or capital taxed twice by two different countries. Because the economic and tax environment is constantly changing, articles and commentary in this model convention are periodically updated. The full-length version of the OECD Model Tax Convention is now available electronically. This new electronic version includes such features as extensive internal linking, making it easy to link from an article to its commentary; fast searching capabilities; the ability for the user to attach notes to specific areas of text; and cut and paste capabilities. The full-length version is also produced in a loose-leaf format to accommodate regular updates.
Book Synopsis Special Features of the UN Model Convention by : Anna Binder
Download or read book Special Features of the UN Model Convention written by Anna Binder and published by Linde Verlag GmbH. This book was released on 2019-10-01 with total page 582 pages. Available in PDF, EPUB and Kindle. Book excerpt: Detailed research on the UN Model Convention’s unique features The UN Model Convention has a significant influence on international tax treaty practice and is especially used by emerging and developing countries as a starting point for treaty negotiations. Driven by the aim to achieve consistency in the international tax treaty practice, the structure and content is, to a large extent, similar in the UN Model and the OECD Model. However, whereas the OECD has historically focused its efforts on issues mainly relevant for developed countries, the UN Tax Committee has continuously attempted to specifically take into account tax treaty policies for developing countries when drafting and amending the UN Model Convention. Compared to the OECD Model Convention, the UN Model Convention aims at giving more weight to the source principle. Popular examples are the PE definition in the UN Model which provides for a lower threshold than Article 5 of the OECD Model or Article 12A on Fees for Technical Services which has been introduced with the latest amendment of the UN Model Convention 2017 and allows for a withholding tax to be levied on payments to non-residents when the payer of the fee is a resident of that contracting State irrespective of where the services are provided. Interestingly, in the discussions of the tax challenges arising from the digitalization of the economy, the OECD and the G20 are also exploring options to allocate more taxing rights to the jurisdiction of the customer and/or user, i.e., the ‘market jurisdictions’. As this has traditionally been the focus of the UN Model Convention, its unique features and developing countries’ practices could be taken into account when exploring new nexus rules that are not constrained by the physical presence requirement. This book contains the master’s theses of the full-time LL.M. program 2018-2019 for which ‘Special Features of the UN Model Convention’ has been chosen as the general topic. With this book, the authors and editors do not aim at discussing each article of the UN Model Convention but rather focus on the unique features of the UN Model Convention, which are explored in detail. This is supplemented with an evaluation of the function and relevance of the UN Tax Committee in the international tax policy discussion and with an analysis of the influences of the OECD's BEPS project on the UN Model.
Book Synopsis The Use and Interpretation of Tax Treaties in the Emerging World by : Eduardo A. Baistrocchi
Download or read book The Use and Interpretation of Tax Treaties in the Emerging World written by Eduardo A. Baistrocchi and published by . This book was released on 2013 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: Certain parts of the international tax system are largely unexplored from a structural perspective. One prominent example is the asymmetric tax treaty network, i.e. the network that consists of bilateral tax treaties concluded between developed and emerging countries on the basis of the OECD Model Tax Convention on Income and on Capital (OECD model). The relative size of this network is substantial. For instance, the United Kingdom's asymmetric tax treaty network represents about 72 per cent of its entire tax treaty network.This article offers a structural analysis of the asymmetric tax treaty network. It answers two fundamental questions. First, it elaborates a theory for explaining why a representative emerging country is willing to conclude tax treaties with developed countries on the basis of the OECD model. Secondly, this article extends that theory to understanding the dynamics of tax treaty interpretation in the emerging world. This extension aims to illuminate the structure of incentives the courts of a representative emerging country normally have when construing OECD-based tax treaties in the foreign direct investment (FDI) area. Game theory is used as a theoretical framework for answering both questions.
