Looking for a tax treaties? Have a look at this 2022 guide!
When you want to find tax treaties, you may need to consider between many choices. Finding the best tax treaties is not an easy task. In this post, we create a very short list about top 8 the best tax treaties for you. You can check detail product features, product specifications and also our voting for each product. Let’s start with following top 8 tax treaties:
Best tax treaties
1. The OECD Multilateral Instrument for Tax Treaties: Analysis and Effects
Description
The Multilateral Instrument (MLI) proposed in OECD BEPS Action 15 will lead to the modification of numerous tax treaties. As tax treaties can have different wording, terminology and structure, a great challenge is to find a proper way to accomplish their modification without distorting the underlying framework or triggering undesirable effects.
This book analyses the MLI, which was signed by over seventy jurisdictions on 7 June 2017. The topics covered include:
- the procedural mechanisms on how the new measures to prevent base erosion and profit shifting (BEPS) will interact with and complement existing tax treaties;
- the scope of the MLI in order to ascertain which tax treaties and taxes are covered;
- the interpretation of terms used in the MLI and the relationship between the languages used in the MLI and in the particular tax treaties;
- the implementation of the minimum standard through the MLI, as well as how states can exercise various options offered by the MLI and reserve the right not to apply certain provisions of the MLI;
- the legal consequences of the exercise of options and reservations for the other states;
- the notification procedure through which states declare their choices; and
- the possibilities and procedure for withdrawal from the obligations entered into upon signing the MLI.
Finally, the book discusses whether the mechanism of the MLI can serve as a role model for future changes to the OECD Model Convention.
The book incorporates the analyses of leading scholars and practitioners dealing with international tax matters. Critical insights are offered for academics, practitioners, tax officials and judges who deal with or are interested in the field of international taxation.
2. 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 .
3. 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.
4. 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.5. 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.6. Tax Treaty Case Law Around the Globe (Eucotax Series on European Taxation)
Feature
Tax Treaty Case Law Around the Globe 2011Description
Although tax treaties may look similar because they are usually based on model tax conventions, clear differences in interpretation and application become evident in the diversity of court decisions on tax treaty issues worldwide. In this book, outstanding experts from over thirty jurisdictions discuss the most relevant recent court decisions taken in their countries. The contributions, focusing on the potential impact of the judgments on the interpretation and application of tax treaties in other countries, cover such important aspects as the following:- residence requirements;
- cross-border partnerships;
- characterization of interest payments;
- transfer pricing;
- royalties;
- directors' fees;
- artistes' and sportsmen's income;
- students' income; and ;
- compensation of losses.
Each discussion gives the facts of each case (many of the cases are not accessible in English), the reasoning of the court, and the author's observations. The systematic structure of each report allows different tax treaty case law to be studied and compared in a simple and efficient way--something that has never been done this comprehensively before. With the continuously increasing importance of tax treaties, this global overview of international tax disputes on double tax conventions is a valuable resource for practitioners and academics active in tax treaty case law. It will also be of value for multinational businesses, policymakers, and tax administrations as a source of alternative approaches and best practice models.
7. Permanent Establishments. A Domestic Taxation, Bilateral Tax Treaty and OECD Perspective
Description
Permanent Establishments (PEs) are a key facet of international taxation. They constitute the crucial threshold for the assignment of taxing rights to a jurisdiction in all cases of enterprises operating in more than one country. The issue of whether there is a PE, and how much profit should be allocated to it, is an increasingly important factor in tax planning, tax accounting, tax compliance, and related tax risk management.
Groundbreaking developments have reshaped the face of the classical PE concept during the year 2017. Following action item no. 7 of the Anti-BEPS efforts of G20 and OECD, the OECD has presented the Multilateral Instrument (MLI) on Base Erosion and Profit Shifting in June 2017. Based on the MLI as well as earlier drafts, Article 5 of the OECD Model Tax Convention and the Official Commentary have been amended in November 2017. Similarly, Article 7 of the OECD Model Tax Convention on the allocation of income in PE situations is influenced by the October 2015 OECD BEPS proposals.
This academically rigorous yet thoroughly practical work provides comprehensive guidance on a variety of complex PE issues. Its initial chapters analyse the latest OECD and EU developments in the context of Articles 5 and 7 of the OECD Model Tax Convention. 21 country chapters cover domestic PE issues as well as country-specific treaty developments from a practical perspective.
8. A Multilateral Tax Treaty: Designing an Instrument to Modernise International Tax Law (Series on International Taxation)
Description
About this book:
A Multilateral Tax Treaty addresses the legal and political aspects of a multilateral convention in the field of international taxation. Many states have set out to develop a multilateral tax instrument with the purpose of amending bilateral treaties in a quick and comprehensive manner. The recent adoption by as many as 100 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 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. In doing so, it also explains and evaluates the OECD Multilateral Instrument, addresses its procedural elements, and the practical issues relating to its implementation.
Whats in this book:
Drawing on the fields of international law, international relations, and political science, the author has developed 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.
How this will help you:
This book discusses in depth the phenomenon of multilateral cooperation in international taxation and the far-reaching implications of the international tax reform currently underway. In combination with its focus on procedural issues such as opt-outs and reservations, the structural solution presented enables the reader to evaluate the multilateral reform currently underway and to understand the legal and political angles of the implementation of the OECD Multilateral Instrument. The authors original research and his recommendations for future development of the topic offer deeply informed guidance to policymakers, practitioners and other tax professionals, and academics.
Recent Comments