Tax Treaty Case Law around the Globe 2017

S. VPreface

Both the OECD Model Tax Convention on Income and Capital (OECD Model) and the United Nations Model Double Taxation Convention (UN Model) often serve as a basis for tax treaty negotiations between different jurisdictions worldwide. At the same time, however, and for a number of reasons, the interpretation of a particular tax treaty provision may still differ from country to country. Therefore, the risk of double or even multiple (non-) taxation is not fully eliminated. In order to promote a uniform interpretation of tax treaties worldwide and, hence, to reduce the risk of double or 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 can 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 officials.

On 27-29 April 2017, the conference “Tax Treaty Case L...