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Klaus Vogel on Double Taxation Conventions, 5th Edition

Klaus Vogel on Double Taxation Conventions, 5th Edition

  • Author:
  • Publisher: Kluwer Law International
  • ISBN: 9789403513003
  • Published In: February 2022
  • Format: Hardback
  • Jurisdiction: International ? Disclaimer:
    Countri(es) stated herein are used as reference only

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  • Description 
  • Contents 
  • Author 
  • Details

    Klaus Vogel on Double Taxation Conventions is regarded as the international gold standard on the law of tax treaties. This article-by-article commentary has been completely revised and updated to give you a full and current account of double tax conventions (DTCs).

     

    DTCs form the backbone of international taxation, but they raise many interpretational questions. This market leading work will provide you with the answers.

     

    Based on the OECD/G20 Multilateral Instrument, the OECD MC and Commentary published in 2017 and the most recent amendments to the UN MC, the book also includes relevant case law and scholarly literature upto and including 2020.

     

    Previous editions of the Vogel have been routinely relied on by courts around the world including Australia, Canada, Germany, India, South Africa, the Netherlands and United Kingdom.

     

    What’s new in this edition?

     

    There have been many important developments in this area since the last edition in 2015. The authors discuss these developments and the effect they will have upon practitioners working in this area. They also provide a wealth of new and revised case law, along with the DTCs of emerging countries.

     

    You’ll find:

    • Reports about major features in the DTC practice of many leading jurisdictions, such as:
      • the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US
      • Sections on divergent country practice covering their national models and networks of bilateral DTCs
    • Thorough analysis of the OECD and UN model, as well as the implementation of these models in practice
    • Amendments of bilateral DTCs, textual or in substance, on the basis of the 2017 Anti-BEPS Multilateral Instrument
    • Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries

     

    This new Fifth Edition of Klaus Vogel on Double Taxation Conventions continues to reflect the unchallenged role of the OECD. The OECD MC, accompanied by the official Commentary, guidelines, reports and other recommendations, has sustained its position as the most important legal instrument in the area of DTCs.

     

    On occasion, the UN MC and Commentary diverge from the OECD texts. When this happens, the authors deal with the specifics of the UN MC in separate annotations and analyses, explaining and making sure you understand the differences.

     

    How this will help you:

     

    • All the information you need to confidently advise on issues such as the taxation of income, taxation of capital and the elimination of double taxation
    • Know that your advice to clients is based on the most up-to-date and respected information available, from an outstanding team of editors and authors

    The editors, Professors Ekkehart Reimer and Alexander Rust, have worked with the late Professor Vogel as well as an international team of top experts to completely update and enhance the content. The writing team comprises:

  • Volume I

    Preface

    Acknowledgments

    List of Abbreviations

    Introduction

    Chapter I. Scope of the Convention

    Article 1. Persons Covered

    Article 2. Taxes Covered

    Chapter II. Definitions

    Article 3. General Definitions

    Article 4. Resident

    Article 5. Permanent Establishment

    Chapter III. Taxation of Income

    Article 6. Income from Immovable Property

    Article 7. Business Profits

    Article 8. International Shipping and Air Transport

    Article 9. Associated Enterprises

    Preface to Articles 10 to 12

    Article 10. Dividends

    Article 11. Interest

    Article 12. Income from Royalties

    Article 13. Capital Gains

    Ex-Article 14. Independent Personal Services

    Volume II

    Article 15. Income from Employment

    Article 16. Directors’ Fees/Directors’ Fees and Remuneration of Top-Managerial Officials

    Article 17. Entertainers and Sportspersons

    Article 18. Pensions

    Article 19. Government Service

    Article 20. Students

    Article 21. Other Income

    Chapter IV. Taxation of Capital

    Article 22. Capital

    Chapter V. Methods for Elimination of Double Taxation

    Article 23A. Exemption Method

    Article 23B. Credit Method

    Chapter VI. Special Provisions

    Article 24. Non-discrimination

    Article 25. Mutual Agreement Procedure

    Article 26. Exchange of Information

    Article 27. Assistance in the Collection of Taxes

    Article 28. Members of Diplomatic Missions and Consular Posts

    Article 29. Entitlement to Benefits

    Article 30. Territorial Extension

    Chapter VII. Final Provisions

    Article 31. Entry into Force

    Article 32. Termination

    Index

  • Editors:

     

    Prof. Dr Ekkehart ReimerHeidelberg University and Prof. Dr Alexander RustWU Vienna.

     

    Authors:

     

    Johannes BeckerFederal Ministry of Finance, BerlinAlexander BlankUniversity of Erlangen-NurembergKatharina BlankFederal Ministry of Finance, BerlinMichael BlankUniversity of Erlangen-NurembergProf. Dr Luc De Broe, Catholic University of Leuven; Laga; Prof. Dr Axel Cordewener, Catholic University of Leuven and Flick Gocke Schaumburg ; Prof. Dr Ana Paula DouradoUniversity of LisbonDaniela Endres-Reich, University of Erlangen-NurembergProf. Dr Werner HaslehnerUniversity of LuxembourgProf. Dr Roland IsmerUniversity of Erlangen-NurembergProf. Dr Eric C. C. M. Kemmeren , Tilburg UniversityProf. Dr Georg KoflerWU ViennaSophia PiotrowskiUniversity of Erlangen-NurembergProf. Dr Ekkehart Reimer, Heidelberg University;  Prof. Dr Alexander RustWU ViennaAnnika StreicherWU ViennaProf. Dr. Matthias ValtaDuesseldorf UniversityJens WittendorffErnst & Young, Copenhagen and University of AarhusKamilla ZembalaHeidelberg University

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