Author Description

Tax Treaty Case Law around the Globe 2013 comprises the proceedings of a conference held in Vienna, Austria, on 23-24 May 2013. This book provides a comprehensive global overview of international tax disputes on double tax conventions. It covers the thirty-six most important tax treaty cases which were decided during the course of 2012 around the world. The systematic structure of each case allows easy and efficient comparison of the various applications and interpretations of tax treaties in different regimes. The book is divided into eight parts: (1) personal and substantive scope (arts. 1, 2 and 4 OECD Model), (2) permanent establishments (art 5 OECD Model), (3) business profits and associated enterprises (arts. 7 and 9 OECD Model), (4) royalties (art. 12 OECD Model), (5) dividends, interest and capital gains (arts. 10, 11 and 13 OECD Model), (6) employment income (arts. 15, 18 and 19 OECD Model); directors' fees, artistes and sportsmen, students and other income (arts. 16, 17, 20, 21 OECD Model), (7) non-discrimination (art. 24 OECD Model) and (8) methods to avoid double taxation, mutual agreement procedure, exchange of information and assistance in the collection of taxes (arts. 23, 25, 26 and 27 OECD Model).