Author Description

This book gives a global overview of international tax disputes on double tax conventions. It covers 35 tax treaty cases that were decided around the world in 2017. Part 1: Scope, interpretation, tax treaty abuse, residence. Part 2: Permanent establishment. Part 3: Business profits and capital gains. Part 4: Labour income, pensions, sportsmen, students and other payments. Part 5: Royalties. Part 6: Relief from double taxation, LoB and subject-to-tax requirement. Part 7: Non-discrimination, exchange of information and MAP.