Contents:
Chapter 1: An Overview of International Taxation
What is International Taxation?
International Tax Conflicts and Double Taxation
Double Tax Treaties
Domestic Tax Systems
International Offshore Financial Centres
Anti-avoidance Measures
International Tax Planning
Structure of the Book
Suggested Further Reading
i OECD Publications
iiTax Journals
iii Websites
Chapter 2: Principles of International Tax Law
International Tax Law
Application of Tax Treaties
Interpretation of Tax Treaties
Some Legal Decisions on Treaty Interpretations
Model Tax Conventions
Multilateral Tax Agreements
European Union
Harmful Tax Competition
Suggested Further Reading
Chapter 3: Model Tax Conventions on Double Tax Avoidance
OECD Model Convention on Income and Capital ("OECD MC")
UN Model Convention ("UN MC")
US Model Convention ("US MC")
Articles in the Model Conventions
Bilateral Tax Treaties
Suggested Further Reading
Chapter 4: Impact of Domestic Tax Systems
Introduction
Tax Residence or Fiscal Domicile
Source of Income or Gain
Basis of Tax Computation
Treatment of Tax Losses
Advance Tax Rulings
Passive Income
Foreign Tax Relief
Suggested Further Reading
International Tax Glossary
Exhibits - Model Tax Treaties
OECD Model Tax Convention on Income and on Capital (January 28, 2003)
United Nations Model Tax Convention between Developed and Developing Countries (January 11, 2001)
United States Model Income Tax Convention (September 20, 1996)
League of Nations Draft Treaties 1928 - 1946
Andean Model
Index to Volume One |