Multilateral Tax TreatiesKluwer Law International B.V., 1998 M04 22 - 250 pages Differing provisions in bilateral tax treaties lead to undesired consequences. Tax administrations expend considerable energy combating tax structures devised by taxpayers and their advisers who attempt to use these differences to their advantage. This battle uselessly engages the resources of both enterprises and tax authorities. A model multilateral tax treaty could provide the solution to this problem. The advantages and disadvantages of multilateral tax treaties have been debated for many years. While some multilateral tax treaties have been concluded at regional levels, the concept has yet to gain wide acceptance. Multilateral Tax Treaties results from a research project conducted at the Department for Austrian and International Tax Law at the University of Economics and Business Administration in Vienna. The project sought to produce a draft multilateral tax treaty modeled on the OECD Model Income Tax Convention while examining in detail difficulties that arise in connection with the multilateralisation of the OECD Model. The expert papers also present a thorough analysis of the arguments for and against the conclusion of a multilateral tax treaty and of the various European law issues that arise in this context. Multilateral Tax Treaties provides incisive and thought-provoking reading for the international tax specialist and generates further discussion on this important topic. |
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1995 OECD Commentary 220 EC Treaty according to Article allocation rules apply arbitration clause Arbitration Convention arbitration procedure arise Article 11 Article 220 EC Article 23 Austria bilateral tax treaties bilateral treaties capital competent authorities concluded with EC Court of Justice credit method discrimination dividends domestic law double taxation convention EC Law EC Member EC Tax Review elimination of double enterprise establishment or fixed European Community European Union exemption method Finland fiscal fixed base Germany grant harmonisation immovable property income derived interest international tax law interpretation jurisdiction Luxembourg ment Model Tax Convention most-favoured-nation multilateral tax treaty multilateral treaty mutual agreement procedure Netherlands non-Member non-resident taxpayers OECD Model Tax Osnabrücker payments provisions of Article remuneration resident taxpayer respect right to tax royalties Steuerrecht tax paid Tax Treaty Draft taxable third countries ticle Treaties and EC triangular United Kingdom withholding tax rate