Title The UN model convention and its relevance for the global tax treaty network / editors, Michael Lang, Pasquale Pistone, Alexander Rust, Josef Schuch, Claus Staringer

Published Amsterdam, The Netherlands : IBFD Publications, [2017]

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Description 1 online resource : illustrations Series WU - tax law and policy series ; vol. 7 WU Institute for Austrian and International Tax Law European and international tax law and policy series ; v. 7. 2451-8360 Contents The relevance of the commentaries on the OECD and UN models for the interpretation of the UN model / David Orzechowski -- Business profits, permanent establishments and associated enterprises / Raffaele Petruzzi and Viktoria Wöhrer -- Independent and dependent personal services / Benjamin Walker and Alexander Rust -- International traffic / Claus Staringer and Matthias Mayer -- Passive income / Anna Binder and Selina Siller -- Capital gains / Peter Bräumann and Michael Tumpel -- Directors' fees and renumeration of top-level managerial officials / Patrick Orlet and Josef Schuch -- Pensions, students and other income / Eline Huisman and Nadine Oberbauer -- Elimination of double taxation / Rita Julien -- Dispute resolution / Laura Turcan -- Exchange of information and mutual assistance in the collection of taxes / Pasquale Pistone and Pedro Guilherme Lindenberg Schoueri Summary 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 Bibliography Includes bibliographical references Notes English Online resource; title from caption (IBFD tax research platform, viewed April 16, 2020) Subject Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs. Model tax convention on income and on capital -- Congresses SUBJECT United Nations model double taxation convention between developed and developing countries -- Congresses Model tax convention on income and on capital (Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs) fast Subject Double taxation -- Congresses Double taxation -- Treaties -- Congresses Double taxation -- Treaties Double taxation Income tax -- Law and legislation Genre/Form Conference papers and proceedings Form Electronic book Author Lang, Michael, 1965- editor. Pistone, Pasquale, editor. Rust, Alexander, editor. Schuch, Josef, editor. Staringer, Claus, editor. International Bureau of Fiscal Documentation, publisher. ISBN 9789087224264 9087224265

Other Titles United Nations model convention and its relevance for the global tax treaty network

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