Tax Treaty Case Law around the Globe 2020

Preface

Both the OECD Model Tax Convention on Income and Capital (OECD Model) and the United Nations Model Double Taxation Convention (UN Model) are designed as tools for legislative harmonization and, therefore, often serve as a basis for tax treaty negotiations between different jurisdictions worldwide. At the same time, however, the interpretation of a particular tax treaty provision may still differ from country to country due to a number of reasons. The risk of double/multiple (non) taxation is, therefore, not entirely removed, and this will adversely affect the international exchange of goods and services and the movement of capital, technology and persons. In order to facilitate a uniform interpretation of tax treaties worldwide and, hence, reduce the risk of double/multiple (non) taxation, basic knowledge is needed on how various tax treaty issues are resolved by different jurisdictions.

It is widely known that a unified approach to the interpretation and application of international tax treaty rules may benefit not only the countries/parties to a certain tax treaty, but also their taxpayers, as well as international trade and investments in general. This topic is, therefore,...