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Klaus Vogel On Double Taxation Conventions, 4th Revised Edition

Klaus Vogel On Double Taxation Conventions, 4th Revised Edition

  • Author:
  • Publisher: Kluwer Law International
  • ISBN: 9789041122988
  • Published In: March 2015
  • Format: Hardback (2 volumes) , 2079 pages
  • Jurisdiction: Austria, Brazil, Canada, China, European Union, France, Germany, India, International, Japan, Netherlands, Russia, Switzerland, U.K., U.S. ? Disclaimer:
    Countri(es) stated herein are used as reference only
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  • Description 
  • Contents 
  • Author 
  • Details

    Klaus Vogel on Double Tax Conventions is regarded as the international gold standard on the law of tax treaties. This new Fourth Edition 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 MC and Commentary published in July 2014, the book also includes relevant case law and scholarly literature from 2014.

    What’s new in this edition?

    There have been many important developments in this area since the last edition in 1997. 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:
    1. the DTC practice of Austria, Canada, France, Germany, India, the Netherlands, Switzerland, the UK and the US
    2. 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
    • Coverage of a full range of the latest tax treaties around the world, including important treaties between OECD and BRICS countries

    This new edition 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
  • 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-Residence

    Article 5. Permanent Establishment

    Chapter III. Taxation of Income

    Article 6. Income from Immovable Property

    Article 7. Business Profits

    Article 8. Shipping, Inland Waterways Transport and Air Transport

    Article 9. Associated Enterprises

    Preface to Articles 10-12

    Article 10. Dividends

    Article 11. Interest

    Article 12. Royalties

    Article 13. Capital Gains

    Ex-Article 14. Independent Personal Services

    Article 15. Income from Employment

    Article. 16. Directors’ Fees

    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 23 A. Exemption Method

    Article 23 B. 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. Territorial Extensions

    Chapter VII. Final Provisions

    Article 30. Entry into Force

    Article 31. Termination

    Index

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

    Editors:

    Prof. Dr. Ekkehart ReimerHeidelberg University and Prof. Dr. Alexander Rust,WU Vienna.

    Authors:

    Johannes BeckerHeidelberg University

    Dr Alexander Blank , Rödl und Partner, Nuremberg

    Michael BlankLLM (Cantab.)University of Erlangen-Nuremberg

    Prof. Dr Luc De Broe , Catholic University of Leuven; Laga, Brussels

    Prof. Dr Axel CordewenerLLM, Of Counsel, Flick Gocke Schaumburg

    Prof. Ana Paula Dourado,University of Lisbon

    Daniela Endres , University of Erlangen-Nuremberg

    Prof. Dr Werner Haslehner, University ofLuxembourg

    Prof. Dr Roland IsmerMSc Econ. (LSE) , University of Erlangen-Nuremberg

    Prof. Dr Eric C. C. M. Kemmeren , Tilburg University

    Prof. Dr Georg KoflerLLM (NYU) , Johannes Kepler University of Linz;

    Prof. Dr Ekkehart Reimer , Heidelberg University

    Katharina RiemerMinistry of Economics and Finance, Baden-Württemberg

    Prof. Dr Alexander Rust , LLM (NYU),WU Vienna

    Dr Matthias Valta , Heidelberg University

    Kamilla ZembalaHeidelberg University.

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