We spent many hours on research and managed to find top 8 tax treaties that is best suitable for you. This review is based on reliable sources, product specs, and hundreds of customer reviews. In this article, were going to highlight the main features of the best tax treaties and why they are important when it comes to choosing the right one.
Best tax treaties
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1. International Tax Policy and Double Tax Treaties
Description
This book gives the reader an understanding of the concepts that underlie international tax law and double tax treaties.2. Judicial Interpretation of Tax Treaties: The Use of the OECD Commentary (Elgar Tax Law and Practice series)
Description
Judicial Interpretation of Tax Treaties is a detailed, comprehensive analytical guide to the interpretation of tax treaties at the national level. The book focuses on how domestic courts interpret and apply the OECD Commentary to the OECD Model Tax Convention on Income and on Capital. Adopting a global perspective, 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 operates on two levels: Firstly it sets out a clear and comprehensive framework of tax treaty law, which will be an important tool for any tax practitioner. Secondly, the book provides crucial guidance on issues of tax treaty law as applied at domestic level, such as investment or business income, dispute resolution and administrative cooperation.
Key features:
- A detailed and structured introduction to the main issues of tax treaties
- Ideal for practitioners requiring a grounding in the functioning of tax treaty law
- Concise summaries of the relevant issues, cases, and problems for each discrete chapter
- Offers a basic 'globalized' handbook that is missing in the current literature about judicial application of tax treaties.
This comprehensive treatment of tax treaty law is a ready reference for tax practitioners, and an essential introduction for non-specialists. The book can also be used as a companion to courses in international taxation.
3. A Global Analysis of Tax Treaty Disputes 2 Volume Hardback Set (Cambridge Tax Law Series)
Description
This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law. Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases. By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital. Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.4. Other Income under Tax Treaties (Series on International Taxation)
Description
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.
5. Schwarz on Tax Treaties
Description
Schwarz on Tax Treaties is the definitive analysis of tax treaties from a UK perspective and provides in depth expert analysis of the interpretation and interaction of the UK's treaty network with EU and international law in their application to UK tax law.
Schwarz on Tax Treaties has established itself as a standard reference work on this challenging subject. The fifth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, international and EU treaty developments including:
- New Bilateral double tax and exchange of information treaties and protocols
- OECD BEPS Multilateral Instrument
- Treaty binding compulsory arbitration
- State Aid Luxembourg Alleged aid to McDonald s
- Judicial decisions of United Kingdom and foreign courts on UK treaties
- Taxpayer rights in EU exchange of information
- Multilateral MOU on Country-By-Country Reporting
- EU Anti-Tax Avoidance Directive
Case law developments including:
- UK Supreme Court in Miller, R (oao) v Secretary of State for Exiting the EU
- Australian High Court in Bywater Investments Ltd and others v CoT
- Indian Supreme Court in Formula One World Championship Ltd v CIT
- UK Tax Tribunals Irish Bank Resolution Corporation Ltd v HMRC; Fowler v HMRC; R (oa Derrin Brother Properties Ltd), Vrang v HMRC , Ardmore Construction
- CJEU in Austria v Germany; Berlioz Investment Fund SA v Directeur de l'administration des Contributions directes; Eqiom SAS and Enka SA v. Ministre des finances et des comptes
Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian Barrister. His practice focuses on international tax disputes as counsel and advice on solving cross-border tax problems. He is a visiting Professor at King s College London and a member of the Permanent Scientific Committee of the International Fiscal Association. He has been listed as a leading tax Barrister in both the Legal 500 for international corporate tax, and Chambers' Guide to the Legal Profession for international transactions and particular expertise in transfer pricing. He has been lauded in Who's Who Legal, UK Bar for his brilliant handling of cross-border tax problems. In Chambers Guide he is commended for his encyclopaedic knowledge of double tax treaties .
6. A Proposition for a Multilateral Carbon Tax Treaty
Description
This book proposes a multilateral framework through which countries may tax mineral resources (oil, gas and coal) and capture the full polluting potential of those energy resources through the tax. The framework is designed so that the tax is only levied once through the mineral resources' production chain. A compensation mechanism is proposed to account for non-combusted carbon by-products. The book thus addresses which type of tax is the most appropriate to capture oil, gas and coal's polluting ability; what the best framework is to propose a multilateral environmental tax; what the best legal instrument is to support an environmental tax applied under the defined terms; the compatibility of the proposed tax with international trade regulations; and which is the most suitable intergovernmental organization to host the legal instrument and to administer the aforementioned tax. The research draws from the existing principles of environmental regulations and international environmental agreements (such as the UN Framework Convention on Climate Change, the Kyoto Protocol and the Paris Agreement) to place the proposed Multilateral Carbon Tax Treaty within the framework of environmental protection and establish a dialogue between the environmental legal framework and the proposed tax instrument of resource mobilization. The book further explains why the Paris Agreement has provided the international community with the right momentum for a new tax framework to be adopted within the dual context of tax and environmental law. The legitimacy of the tax as proposed in the multilateral instrument is addressed from tax, trade and environmental perspectives, covering all angles for admissibility of the tax. The book further discusses how the revenues from the tax might be used to stimulate the use of renewable energy resources.7. Non-discrimination and Trade in Services: The Role of Tax Treaties
Description
8. Taxation of Shipping and Air Transport in Domestic Law, EU Law and Tax Treaties
