Tax Treaty Case Law around the Globe 2013

Editor’s Preface

Both the OECD Model Tax Convention on Income and Capital (OECD MC) and the United Nations Model Double Taxation Convention (UN MC) often serve as a basis for tax treaty negotiations between different jurisdictions worldwide. At the same time, however, interpretation of a particular tax treaty provision may still differ from country to country due to a number of reasons. Therefore, the risk of double/multiple (non-)taxation is not fully removed. In order to promote a uniform interpretation of tax treaties worldwide and, hence, to reduce the risk of double/multiple(non-)taxation, basic knowledge is needed on how various tax treaty issues are solved in different jurisdictions. It is widely known that a unified approach to interpretation and application of international tax treaty rules may benefit not only the countries which are parties to the tax treaty in question but also their taxpayers, as well as international trade and investment in general. Therefore, this topic is of ongoing concern to many tax scholars, practitioners, representatives of international organizations and public officers.

On 23-24 May 2013, the conference „Tax Treaty Case Law around the Globe“ wa...