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A Global Analysis of Tax Treaty Disputes

A Global Analysis of Tax Treaty Disputes

作者： Eduardo Baistrocchi
出版商： Cambridge University Press
ISBN: 9781316507254
出版时间 August 2017
规格： Hardback (2 volumes) , 1761 pages
适应领域： International ? 免责申明：
Countri(es) stated herein are used as reference only

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This two-volume set offers an in-depth analysis of the leading tax treaty disputes in the G20 and beyond within the first century of international tax law.

Including country-by-country and thematic analyses, the study is structured around a novel global taxonomy of tax treaty disputes and includes an unprecedented dataset with over 1500 leading tax treaty cases.

By adopting a contextual approach the local expertise of the contributors allows for a thorough and transparent analysis. This set is an important reference tool for anyone implementing or studying international tax regulations and will facilitate the work of courts, tax administrations and practitioners around the world. It is designed to complement model conventions such as the OECD Model Tax Convention on Income and on Capital.

Together with Resolving Transfer Pricing Disputes (2012), it is a comprehensive addition to current debate on the international tax law regime.
- Provides law-in-context analysis of the international tax regime, with contributions from authors working in numerous jurisdictions
- Features country-by-country and topic-by-topic analyses of leading tax treaty disputes
- Includes a comprehensive dataset of over 1,500 leading tax treaty disputes as supplementary material
Volume I: Acknowledgements
List of contributors
List of tables and charts
List of cases
The golden bridge - analytical table of cases by pattern of dispute
Part I. The Context of Tax Treaty Disputes:
1. Introduction Eduardo Baistrocchi
Part II. OECD Countries:
2. Tax treaty disputes in the United States Yariv Brauner
3. Tax treaty disputes in Australia Micah Burch
4. Tax treaty disputes in Canada Arthur J. Cockfield
5. Tax treaty disputes in Chile Ricardo Escobar and Mirenchu Muñoz
6. Tax disputes and the European Union Arbitration Convention Georg Kofler
7. Tax treaty disputes in France Jérôme Monsenego
8. Tax treaty disputes in Germany Werner Haslehner
9. Tax treaty disputes in Ireland Emer Hunt
10. Tax treaty disputes in Italy Carlo Garbarino
11. Tax treaty disputes in Japan Toshio Miyatake
12. Tax treaty disputes in Mexico Oscar Echenique Quintana and Jorge E. Correa Cervera
13. Tax treaty disputes in The Netherlands Kees van Raad, Hans Muste and Frank Pötgens
14. Tax treaty disputes in South Korea Chang Hee Lee and Sunyoung Kim
15. Tax treaty disputes in Switzerland Robert J. Danon
16. Tax treaty disputes in Turkey Billur Yalti
17. Tax treaty disputes in the United Kingdom Timothy Lyons and Jason Whiston.

Volume II:
1. Introduction Eduardo Baistrocchi
Part III. BRICS Countries:
2. Tax treaty disputes in China Yongjun Peter Ni
3. Tax treaty disputes in Hong Kong Michael Littlewood
4. Tax treaty disputes in Brazil Isabel Calich and Joao Dacio Rolim
5. Tax treaty disputes in Russia Irina Dmitrieva
6. Tax treaty disputes in India Aseem Chawla
7. Tax treaty disputes in South Africa Ernie Lai King
Part IV. Countries beyond the OECD and BRICS:
8. Tax treaty disputes in Argentina Manuel M. Benites
9. Tax treaty disputes in Cyprus Christiana H. J. I. Panayi and Margarita Liasi
10. Tax treaty disputes in Uganda Annet Wanyana Oguttu
11. Tax treaty disputes in Indonesia Freddy Karyadi and Danny Darussalam
12. Tax treaty disputes in Saudi Arabia Ehtisham Ahmad and Fahad Al-Kharashi
13. Tax treaty disputes in Singapore Stephen Phua and Chai Sui Fun
Part V. Conclusion:
14. Patterns of tax treaty disputes: a global taxonomy Eduardo Baistrocchi
15. Resolving tax treaty disputes: the global evolutionary path Eduardo Baistrocchi
16. Triple non-taxation and BEPS: global implications Jinyan Li
17. Tax treaty disputes: a global quantitative analysis Eduardo Baistrocchi and Martin Hearson.

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