Buch, Englisch, 272 Seiten
Challenges in a Post-BEPS Multilateral World
Buch, Englisch, 272 Seiten
ISBN: 978-94-035-1836-7
Verlag: Kluwer Law International
In the course of his rigorous commentary, the author invokes the established canons that apply to the interpretation of tax treaties, including the Vienna Convention on the Law of Treaties and the OECD and UN Model Conventions. He presents a detailed investigation of the implications for tax treaty interpretation of such topics and issues as the following:
essential concepts such as “context” and “qualification”;
- evolution of international taxation from bilateralism to multilateralism;
- specific interpretation issues raised by bilateral tax treaties;
- economic crises as drivers for changes in international taxation rules;
- the OECD/G-20 BEPS project;
- digitalization of the economy;
- pandemic, war, and deglobalization;
- interpretation of international treaties versus interpretation of domestic laws; and
- interpretation of double tax conventions in countries that are not OECD members.
In the absence of a declaration of international tax principles, this book’s in-depth analysis of the theory of interpretation of international tax treaties—given the risks of interpreting treaties with different jurisdictions and different languages—will ensure an appropriate understanding of the current context of international taxation, providing practitioners and policymakers with a fully informed background that will guide the interpretation of any international tax treaty.