Priority rules in tax treaties the relationship between the different distributive rules in the OECD and the UN models / Editors: Georg Kofler, Michael Lang, Pasquale Pistone, Alexander Rust, Joseph Schuch, Karoline Spies, Claus Staringer, Rita Szudoczky.

Author/creator Viennese Symposium on International Tax Law
Format Electronic
Publication InfoAmsterdam, the Netherlands : IBFD, [2023]
Descriptionxxii, 389 pages : illustrations ; 23 cm.
Supplemental ContentFull text available from Ebook Central - Academic Complete
Subjects
Double taxation--Treaties.

Other author/creatorKofler, Georg, 1977-
Other author/creatorLang, Michael, 1965-
Other author/creatorLang, Michael, 1965-
Other author/creatorPistone, Pasquale.
Other author/creatorRust, Alexander.
Other author/creatorSchuch, Josef.
Other author/creatorSpies, Karoline, 1986-
Other author/creatorStaringer, Claus.
Other author/creatorSzudoczky, Rita, 1976-
SeriesEuropean and International Tax Law and Policy Series ; Volume 28
European and international tax law and policy series ; v. 28. UNAUTHORIZED
Contents Chapter 1: The role of and the relationship between the distributive rules in tax treaties / Stefano Castagna -- Chapter 2: The relevance of article 7(4) of the OECD Model / Daniel W. Blum and Marcelo H. B. Moura -- Chapter 3: The relevance of article 21(2) of the OECD and UN Models / Georg Kofler and Erika Scuderi -- Chapter 4: The relevance of article 6(4) of the OECD and UN Models / Josef Schuch and Nathalia Oliveira Costa -- Chapter 5: The relevance of articles 10(4), 11(4) and 12(3) of the OECD Model / Daniel W. Blum and Belisa Ferreira Liotti -- Chapter 6: The relationship between articles 7, 8 and 14 of the OECD and UN Models / Abhishek Padwalker and Camilo Rodr©Ưguez Pe©ła -- Chapter 7: The relation between article 12A and article 12B of the UN Model (2021) and the other distributive rules of the UN Model (2021) / Christian Knotzer -- Chapter 8: The relationship between the different distributive rules for employment income / Pasquale Pistone and Stefanie St©œcklinger -- Chapter 9: The relationship between article 16 of the OECD Model and the other distributive rules of the OECD and UN Models / Pasquale Pistone, Siddhesh Rao and J©ơrgen Romstorfer -- Chapter 10: The relation between article 17 of the OECD Model and the other distributive rules of the OECD and UN Models / Monique T. Malan and Alexander Rust -- Chapter 11: The relation between article 20 of the OECD and UN Models and the (other?) distributive rules of the OECD and UN Models / Rainer Borns and Alexander Rust -- Chapter 12: The different distributive rules for capital gains (article 13 of the OECD Model) and for taxes on capital (article 22 of the OECD Model) and their relation to the other distributive rules of the OECD Model / Michael Gleiss -- Chapter 13: The different distributive rules of the OECD Model convention on estates, inheritances and gifts / Yasmin Lawson.
Abstract Thus far, the priority relations between the different distributive rules of the OECD and UN Models have not been comprehensively studied in academia. Nevertheless, the questions of demarcation between the individual provisions are of central importance for the application of a tax treaty. The right of source states to tax and the question of which method is applicable for avoiding double taxation depends on this determination. In some instances, explicit priority rules regulate which distributive rule shall take precedence in the event of overlapping scopes of application between two (or more) distributive rules. Other relations are not specifically dealt with in the OECD and UN Models and are implicit. In both cases, interpretive challenges arise that can only be resolved through intensive analyses of the distributive rules in question. This book aims to provide in-depth analyses of current issues concerning the relations between various distributive rules. The topics covered include: - the role of and the relationship between the distributive rules in tax treaties; - the relevance of article 7(4) of the OECD and UN Models; - the relevance of article 10(4), article 11(4) and article 12(3) of the OECD Model; - the relationship between article 12A and article 12B of the UN Model and the other distributive rules of the UN Model; - the different distributive rules for capital gains (article 13 of the OECD Model) and for taxes on capital (article 22 of the OECD Model) and their relation to the other distributive rules of the OECD Model; and - the different distributive rules of the OECD Model Convention on Estates, Inheritances and Gifts.
Bibliography noteIncludes bibliographical references.
Access restrictionAvailable only to authorized users.
Technical detailsMode of access: World Wide Web
Genre/formElectronic books.
LCCN 2023427288
ISBN9789087228484 (paperback)
ISBN9087228481 (paperback)

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